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Creative Car Park Ltd
Employment Privacy Notice

What is the purpose of this notice?

As your employer we will hold certain information about you. This can range from your bank account information (for the payment of salary) to the holiday you have taken in a given year. We want to hold your information in a transparent way and not hold more of your data than is necessary.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, and is in accordance with the General Data Protection Regulation (GDPR).

This notice applies to current and former employees and workers as well as prospective candidates who are applying to work with us. This does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice that we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

What are the data protection principles?

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

Who will hold my data?

Creative Car Park Limited, is the ‘data controller’ in respect of your personal data. This means that we are responsible for deciding how we hold and use personal information. In the event that you have data concerns you should address them, in the first instance, to the Data Protection Officer.

What data do you envisage collecting?

We may collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
  • Date of birth.
  • Gender.
  • Marital status and dependants.
  • Next of kin and emergency contact information.
  • National Insurance number.
  • Bank account details, payroll records and tax status information.
  • Salary, annual leave, pension and benefits information.
  • Start date.
  • Location of employment or workplace.
  • Copy of driving licence.
  • Details of driving offences and penalties.
  • Details of car registration numbers.
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
  • Employment records (including job titles, work history, working hours, training records and professional memberships).
  • Compensation history.
  • Performance information.
  • Disciplinary and grievance information.
  • CCTV footage and other information obtained through electronic means such as fingerprint scans used for entering the office.
  • Information about your use of our information and communications systems.
  • Photographs.

We may also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Trade union membership.
  • Information about your health, including any medical condition, health and sickness records.
  • Genetic information and biometric data.
  • Information about criminal convictions and offences.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so.

What happens to data which is particularly personal to me?

UK law recognises that “special categories” of particularly sensitive information require a higher level of protection (see list above).

If we collect information of this type we will ensure that it is processed lawfully, fairly and in a transparent manner and collected for a specific purpose. We will endeavour to keep such information up to date and to not hold it for longer than necessary. We generally intend to hold such data during your employment and, upon the termination of your employment for a further six months unless there are good reasons for holding data for an extended period (such as circumstances where there is envisaged or ongoing litigation). At any point you may request that such data is erased or amended.

Given the sensitivity of the data we will also take steps to protect the data against accidental loss, destruction or damage

How will my data be collected?

We will typically collect your data through the application and recruitment process, either directly from you or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies. We sometimes contract with hire companies that use trackers inside their vehicles to record incidents that occur while driving.

We will collect additional personal information in the course of job-related activities throughout the period that you work for us.

When will my data be used?

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. We may, on rare occasions, also use your personal information where we need to protect your interests (or someone else’s interests) or where it is needed in the public interest.

The situations in which we will process your personal information are listed below:

  • Making a decision about your recruitment or appointment.
  • Determining the terms on which you work for us.
  • Checking you are legally entitled to work in the UK.
  • Paying you and, if you are an employee, deducting tax and National Insurance contributions.
  • Providing you with your contractual benefits.
  • Liaising with your pension provider.
  • Administering the contract we have entered into with you.
  • Administering the car park at the office.
  • Business management and planning, including accounting and auditing.
  • Conducting performance reviews, managing performance and determining performance requirements.
  • Making decisions about salary reviews and compensation.
  • Assessing qualifications for a particular job or task, including decisions about promotions.
  • Gathering evidence for possible grievance or disciplinary hearings.
  • Making decisions about your continued employment or engagement.
  • Making arrangements for the termination of our working relationship.
  • Education, training and development requirements.
  • Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
  • Ascertaining your fitness to work.
  • Managing sickness absence.
  • Complying with health and safety obligations.
  • To prevent fraud.
  • To monitor your use of our information and communication systems to ensure compliance with our IT policies.
  • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
  • To conduct data analytics studies to review and better understand employee retention and attrition rates.
  • Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information

The situations in which we will process your particularly sensitive personal information are listed below:

  • To comply with employment and other laws.
  • To assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
  • To provide appropriate workplace adjustments.
  • To monitor and manage sickness absence.
  • To administer benefits.
  • To ensure meaningful equal opportunity monitoring and reporting.
  • To pay trade union premiums.
  • To register the status of a protected employee.

What if I fail to provide personal information?

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers.)

Who will receive my data?

We will endeavour to keep the circulation of your personal data to a minimum. However, your data may be provided to third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Data may be shared with a third party in connection with the provision of your benefits – such as the provision of your information to our insurers or pension providers.

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

We do not propose to transfer your personal data outside of the European Economic Area.

How long will my data be retained?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

In circumstances where you apply for a role with us but are unsuccessful, we will only retain your personal information for as long as necessary to complete the application process. We may, however, retain your contact details on our systems to allow us to contact you in the event that a suitable role arises for which you may be interested in applying.

What rights do I have relating to personal data?

If you have any questions about the way we use your data, you should in the first instance address your concerns to HR or to the Data Protection Officer. It might be that there are steps we can take to explain or amend our processes.

You also have a qualified right under UK law to request: (i) access to your personal data; (ii) the correction or deletion of certain personal data; (iii) that we restrict the processing of data concerning you or; (iv) transfer certain data to other organisations.

We may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Please also note that, if we have requested that you consent to the processing of your personal data you may withdraw this consent at any time by providing notice to us.

Do you use automated systems to make decisions which might impact me in a significant way?

We do not use automated systems to make major decisions about our employees. If we ever do so we will seek to provide you with suitable warning and explanation.

Will my data be kept securely?

We have put in place appropriate security measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Who do I contact if I have a complaint?

Data protection compliance is supervised by the Information Commissioners Office (or “ICO”). In the event that the Data Protection Officer is not able to assist with your queries or you otherwise have a complaint you should contact the ICO.

What do I do if there is a risk of a data breach?

A data breach might occur if the personal data of others is lost, hacked, stolen or otherwise falls into the hands of others outside the business or outside our control.

There are steps which you can take to reduce the risk of a data breach or reduce the risks in the event that a breach occurs. In particular you should:

  • Anonymise data whenever possible
  • Not create personal data if it is unnecessary to do so
  • Always apply passwords to information containing personal data
  • Not take sensitive documents outside of the office unless absolutely necessary
  • Approach you line manager or a member of the IT team if you think that there are ways we can further improve our approach to data security.

What do I do if there is a data breach?

It is important that you inform the Data Protection Officer immediately if you become aware of a data breach or potential breach. The sooner we are notified, the more we can do to minimise the risks and the potential damage. Failure to inform us may amount to gross misconduct and could lead to disciplinary action being taken against you.

You should also consider taking sensible steps to try and remedy the situation provided that this does not involve you putting yourself in harm’s way or increasing the potential seriousness of the breach. By way of example, if you leave a file on the train you should inform an individual from the relevant train company as soon as possible and take normal steps to recover the item in question. It is important that any such steps are taken in parallel with informing the business about the data risk.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will notify you of the new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact HR or the Data Protection Officer.