FOR EMPLOYEES, WORKERS & CONTRACTORS
Kilnbridge understands that your privacy is important to you and that you care about how
your personal data is used. We respect and value the privacy of all of our employees,
workers and contractors and will only collect and use personal data in ways that are
described here, and in a way that is consistent with our obligations and your rights under
the law.
1. What Does This Notice Cover
This Privacy Notice explains how we use your personal data: how it is collected, how it is
held, and how it is processed. It also explains your rights under the law relating to your
personal data.
References to “Kilnbridge”, the “Company”, “we” or “us” shall include Kilnbridge Group
Limited and all its subsidiaries.
This privacy notice applies to current and former employees, workers and contractors.
This notice does not form part of a contract of employment or any contract to provide
services and may be updated at any time.
2. What is Personal Data
Personal data is defined by the General Data Protection Regulation (EU Regulation
2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be
directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be
identified. Personal data covers obvious information such as your name and contact
details, but it also covers less obvious information such as identification numbers,
electronic location data, and other online identifiers.
The personal data that we use is set out in Part 4, below.
3. What Are Your Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This
Privacy Notice should tell you everything you need to know, but you can always
contact us to find out more or to ask any questions.
b) The right to access the personal data we hold about you.
c) The right to have your personal data rectified if any of your personal data held by
us is inaccurate or incomplete.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of
any of your personal data that we have.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or
purposes.
g) The right to data portability. This means that, if you have provided personal data to
us directly, we use it with your consent or for the performance of a contract, and
that data is processed using automated means, you can ask us for a copy of that
personal data to re-use with another service or business in many cases.
Further information about your rights can also be obtained from the Information
Commissioner’s Office, www.ico.org.uk
If you have any cause for complaint about our use of your personal data, you have the
right to lodge a complaint with the Information Commissioner’s Office.
4. What Personal Data Do We Collect
We may collect some or all of the following personal information about you:
• Personal contact details, such as your name, title, address and contact details,
including email address and telephone number;
• date of birth;
• gender;
• the terms and conditions of your employment, contract for services;
• details of your qualifications, skills, experience and employment history, including
start and end dates, with previous employers and with the Company;
• information about your remuneration, including entitlement to benefits such as
pensions;
• details of your bank account, tax status, national insurance number and UTR
number;
• information about your marital status, next of kin, dependants and emergency
contacts;
• information about your nationality and entitlement to work in the UK, which may
include visa, passport or EC ID card;
• copy of driving licence;
• details of periods of leave taken by you, including holiday, sickness absence, family
leave and sabbaticals, and the reasons for the leave;
• details of any disciplinary or grievance procedures in which you have been
involved, including any warnings issued to you and related correspondence;
• assessments of your performance, including appraisals, training you have
participated in, performance improvement plans and related correspondence;
• Facial image, CCTV footage and other information obtained through electronic
means e.g. swipe card records.
We may also collect, store and use the following special categories of more sensitive
personal information:
• information about medical or health conditions, including whether or not you have a
disability for which the Company needs to make reasonable adjustments;
• details of trade union membership;
• Genetic information and biometric data
• information about your criminal record; and
• equal opportunities monitoring information, including information about your ethnic
origin, sexual orientation, health and religion or belief.
The Company collects this information in a variety of ways. For example, data is
collected through the application and recruitment process and during work-related
activities throughout the period of working for us.
In some cases, the Company collects personal data about you from third parties, such
as references supplied by former employers, information from employment background
check providers, information from credit reference agencies and information from
criminal records checks permitted by law.
If you do not provide this data, we may be unable in some circumstances to comply
with our obligations and we will tell you about the implications of that decision.
5. How We Will Use Your Personal Data
Much of the information we hold will have been provided by you, but some may come from
other internal sources, such as your manager, or in some cases, external sources, such as
referees.
We will only use your personal data when the law allows us, for example, to perform our
contract of employment with you and to comply with legal obligations. In some cases we
may use your personal data to pursue legitimate business interests of our own or those of
third parties, provided your interests and fundamental legal rights do not override those
company interests.
The situations in which we will process your personal information include:
• To determine the terms of your appointment and that you are legally entitled to
work in the UK
• Paying you and if you are an employee, deducting tax and National Insurance
contributions
• Providing employment benefits to you and administering your pension
• Administering the contract we have with you
• Equal opportunities monitoring
• Conducting performance reviews, determining training and salary reviews and
compensation
• Assessing qualifications for a particular job or task, including decisions about
training and promotion
• Gathering evidence in relation to any grievance or disciplinary hearings and to
make decisions about your continued employment or engagement
• Dealing with legal disputes, involving you, or other employees, workers or
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
We may also process information where we need to protect your interests (or someone
else’s interest) or where it is required in the public interest or for an official purpose.
6. How We Will Use Particularly Sensitive Personal Data
“Special categories” of particularly sensitive personal information require higher levels of
protection. We may process special categories of personal information in the following
circumstances:
• In limited circumstances, with your explicit written consent.
• Where we need to carry out our legal obligations and in line with our policies
• Where it is needed to assess your working capacity on health grounds, leave of
absence, to provide appropriate workplace adjustments, to monitor and manage
sickness and to administer benefits, subject to appropriate confidentiality
safeguards.
• To ensure meaningful equal opportunity monitoring and reporting, we will use
information about your race or national or ethnic origin, religious, philosophical or
moral beliefs, or sexual orientation.
We may only use information relating to criminal convictions where the law allows us to do
so. Where appropriate we will collect information about criminal convictions as part of the
recruitment process or, where necessary, during the course of employment.
Where we are processing data based on your consent, you have the right to withdraw that
consent at any time.
7. How Long We Will Keep Your Personal Data
The time period for which we keep information varies according to what the information is
used for. In some cases, there are legal requirements to keep data for a minimum period.
Unless there is a specific legal requirement for us to keep the information, we will retain it
for no longer than is necessary for the purposes for which the data was collected.
8. Do We Share Your Personal Data
We will only disclose information about you to third parties if we are legally obliged to do
so, or with your explicit consent, or have a legitimate interest in doing so, or where we
need to comply with our contractual duties to you, for instance we may need to pass on
certain information to pension, health insurance schemes or training providers.
In some limited circumstances, we may be legally required to share certain personal data,
which might include yours, if we are involved in legal proceedings or complying with legal
obligations, a court order, or the instructions of a government authority.
We may share your personal data with other companies in our group for purposes
connected with your employment or the management of the Company’s business. This
includes our holding company and its subsidiaries.
9. How Can You Access Your Personal Data
If you want to know what personal data we hold about you, you can ask us for details of
that personal data and for a copy of it. This is known as a “Subject Access Request”
(SAR).
All Subject Access Requests should be made in writing to the Company Data Protection
Officer.
There is not normally any charge for a Subject Access Request. If your request is
‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee
may be charged to cover our administrative costs in responding.
We will respond to your Subject Access Request within 30 days. Normally, we aim to
provide a complete response, including a copy of your personal data within that time. In
some cases, however, particularly if your request is more complex, more time may be
required up to a maximum of three months from the date we receive your request. You will
be kept fully informed of our progress.
10. How Does The Company Protect Your Data
The Company takes the security of your data very seriously. The Company has internal
policies and controls in place to prevent your data being lost, accidentally destroyed,
misused or disclosed, and is not accessed except by its employees in the performance of
their duties.
When the Company engages third parties to process personal data on its behalf, they do
so on the basis of written instructions, that they operate under a duty of confidentiality and
are obliged to implement appropriate technical and organisational measures to ensure the
security of data.
11. Your Duty to Inform Us of Changes
It is important that the personal information we hold about you is accurate and current.
Please be sure to keep us informed if your personal information changes during your time
working with us.
12. How Do You Contact Us
To contact us about anything to do with your personal data and data protection, including
to make a Subject Access Request, please address to the Data Protection Officer using
the following details:
Email address: DPO@kilnbridge.com
Telephone number: 0207 511 1888.
Postal Address: McDermott House, South Crescent, Cody Road,
Business Park, London, E16 4TL.
13. Information About Us
Kilnbridge Group Limited.
Registered in England under company number 02846010.
Registered address: McDermott House, Cody Road Business Park, South Crescent,
London, E16 4TL
14. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for
example, if the law changes, or if we change our business in a way that affects personal
data protection. We will inform you if there are any substantial changes to this Privacy
Notice.
I acknowledge receipt of the Privacy Notice for employees and contractors and confirm
that I have read and understood it.