Privacy Notice

This privacy notice explains how we use any personal information we collect about you when you use this website / subscribe to our newsletter, apply for a job through BWA People Ltd or become an employee of BWA People Ltd.

What is Personal data?

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “Any information relating to an identified or identifiable natural person ('data subject');

an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”. 

Data protection principles

In relation to your personal information, we will: 

• process it fairly, lawfully and in a clear, transparent way
• collect your information only for reasons that we find proper for the course of your job application in ways that have been explained to you
• only use it in the way that we have told you about
  
• ensure it is correct and up to date
• keep your information for only as long as we need it
• process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed

What information do we collect about you?

Website / email newsletter users

We collect the following information about you when you sign up to receive our newsletter and when you get in contact with us via the form on the contact page of the website:

• your personal details including your name and email address
• the date you signed up to our newsletter

We also collect website usage information when you use this website through the use of cookies.

Job applicants

We hold the following types of information about you as part of any recruitment process:  

• your personal details including your name, address, date of birth, email address, phone number
• information included on your CV including references, education history and employment history
• whether or not you have a disability (for the sole purpose of making reasonable adjustments during the recruitment process).
• documentation relating to your right to work in the UK (including passports, visas)
• details of job offers
• email correspondence related to any recruitment process

Employees

We hold many types of information about you, including:  

• your personal details including your name, address, date of birth, email address, phone numbers
• your photograph
• gender
• marital status
• dependants, next of kin and their contact numbers
• medical or health information including whether or not you have a disability (for the sole purpose of making reasonable adjustments)
• information used for equal opportunities monitoring about your sexual orientation, religion or belief and ethnic origin
• information included on your CV including references, education history and employment history
• documentation relating to your right to work in the UK
• driving licence
• bank details
• tax codes
• National Insurance number
• current and previous job titles, job descriptions, pay grades, pension entitlement, hours of work and other terms and conditions relating to your employment with us
• contracts of employment
• quotations for employment
• leave records including annual leave, family leave, sickness absence etc
• hours worked (timesheets)
• details of your criminal record

How do we collect data about you?

Website / email newsletter users

We collect information about you when you sign up to receive our newsletter and when you get in contact with us via the form on the contact page of the website. Website usage information is collected using cookies.

Job applicants

We collect information about you when you apply for jobs through online job boards or directly to BWA People including the information you would normally include in a CV and a job application cover letter, notes made by us during a recruitment interview or information from psychometric tests. 

In some cases, we will collect information about you from third parties, such as former employers when gathering references. 

Personal information is kept in personnel files or within the Company’s HR and IT systems.

Employees

We collect information directly from you when you complete forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence. Further information relating to your employment will be collected from the client company at which you are located.

In some cases, we will collect data about you from third parties, such as former employers when gathering references. 

Personal information is kept in personnel files or within the Company’s HR and IT systems.

How will we use the information about you?

Website / email newsletter users

We collect information about you to email you about HR topics that we think may be of interest to you or to enable us to get in touch with you after you’ve made contact with us via our contact form.

We use a third party service called MailChimp to send out our newsletter and administer our mailing list. You can view their privacy policy here - https://mailchimp.com/legal/pr...

Job applicants

The law on data protection allows us to process your information for certain reasons only:  

• in order to perform the recruitment agreement that we are party to
• in order to carry out legally required duties
• in order for us to carry out our legitimate interests
• to protect your interests and
• where something is done in the public interest. 

All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data. 

We need to collect your information to ensure we are complying with legal requirements such as:  

• carrying out checks in relation to your right to work in the UK and
• making reasonable adjustments for disabled employees.

We also collect information so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:  

• making decisions about who to shortlist for interviews
• making decisions about who to recommend for roles with our clients
• making decisions about salary and other benefits
• to inform you of suitable opportunities that arise in the future
• dealing with legal claims made against us If you are unsuccessful in obtaining employment, we will seek your consent to retaining your information in case other suitable job vacancies arise in the Company for which we think you may wish to apply. You are free to withhold your consent to this and there will be no consequences for withholding consent.

Employees

The law on data protection allows us to process your data for certain reasons only:  

• in order to perform the employment contract that we are party to
• in order to carry out legally required duties
• in order for us to carry out our legitimate interests
• to protect your interests and
• where something is done in the public interest. 

All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.  

For example, we need to collect your personal information in order to:  

• carry out the employment contract that we have entered into with you and
• ensure you are paid. 

We also need to collect your information to ensure we are complying with legal requirements such as: 

• ensuring tax and National Insurance is paid
• carrying out checks in relation to your right to work in the UK and
• making reasonable adjustments for disabled employees. 

We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:  

• making decisions about who to offer initial employment to, and subsequent internal appointments, promotions etc
• making decisions about salary and other benefits
• providing contractual benefits to you
• maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained
• offering a method of recourse for you against decisions made about you via a grievance procedure
• implementing an effective sickness absence management system including monitoring the amount of leave and subsequent actions to be taken including the making of reasonable adjustments
• gaining expert medical opinion when making decisions about your fitness for work
• managing statutory leave and pay systems such as maternity leave and pay etc
• dealing with legal claims made against us
• preventing fraud
• ensuring our administrative and IT systems are secure and robust against unauthorised access

Special categories of data

Job applicants & Employees

Special categories of data are information relating to your:  

• health
• sex life
• sexual orientation
• race
• ethnic origin
• political opinion
• religion
• trade union membership and
• genetic and biometric data 

We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies: 

• you have given explicit consent to the processing
• you have already made the information public
• we must process the information in order to carry out our legal obligations
• we must process information for reasons of substantial public interest 

We will use your special category data:  

• for the purposes of equal opportunities monitoring
• to ensure compliance with your statutory rights
• to comply with statutory and / or legal obligations 
  

We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

Criminal conviction data

Job applicants & Employees

We will only collect criminal conviction data where it is appropriate given the nature of the role you are applying for and where the law permits us. This data will be collected at the recruitment stage and with your consent. We use criminal conviction data in the following ways:  

• to assess your suitability for a job role
• to ensure compliance with your statutory rights
• to comply with statutory and / or legal obligations 

We rely on the lawful basis of the need to establish, exercise or defend a legal claim to process this data.

If you do not provide your information to us

Job applicants

One of the reasons for processing your information is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not able to process, or continue with (as appropriate), your application.

Employees

One of the reasons for processing your information is to allow us to carry out our duties in line with your contract of employment. If you do not provide us with the information needed to do this, we will unable to perform those duties eg ensuring you are paid correctly. We may also be prevented from confirming, or continuing with, your employment with us in relation to our legal obligations if you do not provide us with this information eg confirming your right to work in the UK or, where appropriate, confirming your legal status for carrying out your work via a criminal records check.

Sharing your information

Website / email newsletter users

BWA People will not share your information for marketing purposes with any other companies.

We use a third party service called MailChimp to send out our newsletter and administer our mailing list. You can view their privacy policy here - https://mailchimp.com/legal/pr... 

The information you provide when subscribing to our newsletter may be stored outside of the European Economic Area. We do not share your subscriber information with any other bodies outside of the European Economic Area.

Job applicants

Your information will be shared with colleagues within the Company where it is necessary for them to undertake their duties with regard to recruitment. This includes the Director of the company during the recruitment and selection process. 

In some cases, we will collect information about you from third parties, such as employment agencies. 

Your information will be shared with client companies with whom you have applied and been shortlisted for a job as part of the recruitment process.  If your application is successful we may share your information with other third parties in order to obtain references as part of the recruitment process.

Your job applicant information may be stored outside of the European Economic Area by third party cloud services, Dropbox and Podio. You can view their privacy policies here -

https://www.dropbox.com/terms#...

https://www.citrix.com/about/l...

We do not share your job applicant information with any other bodies outside of the European Economic Area.

Employees

Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties relating to your contract of employment. This includes, for example, maintaining personnel records and the payroll for administering payment under your contract of employment.  

Your data will be shared with client companies that you undertake work for as a contract employee of BWA People Ltd in order to fulfil the duties relating to your contract of employment.  

We may share your data with third parties in order to obtain references as part of the recruitment process. We may also share your data with our auto-enrolment pension provider in order to fulfil our legal obligation to provide an auto-enrolment pension to our qualifying employees.

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us.  

Your employee information may be stored outside of the European Economic Area by third party cloud services, Dropbox and Podio. You can view their privacy policies here -

https://www.dropbox.com/terms#...

https://www.citrix.com/about/l...

We do not share your employee information with any other bodies outside of the European Economic Area.

Protecting your information

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such, these policies and processes are: Data Protection Policy, Data transfer security policy, Data breach notification policy, Data deletion request form, Data rectification request form, Data restriction request form.

Where we share your data with third parties, we ensure that your information is held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

How long we keep your information for

Job applicants

In line with data protection principles, we only keep your information for as long as we need it for and this will depend on whether or not you are successful in obtaining employment with roles you have applied for through BWA People Ltd.  

If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your information for the purpose of future suitable job vacancies, we will keep your information for six months once the recruitment exercise ends.  

If we have sought your consent to keep your information on file for future job vacancies, and you have provided consent, we will keep your information for one year once the recruitment exercise ends. At the end of this period, we will delete or destroy your information, unless you have already withdraw your consent to our processing of your information in which case it will be deleted or destroyed upon your withdrawal of consent.

Employees

In line with data protection principles, we only keep your information for as long as we need it for, which will be at least for the duration of your employment with us though in some cases we will keep your information for a period after your employment has ended. Retention periods can vary depending on why we need your data, as set out below:  

• Personal details: Up to 6 months after the end of employment (1 year with your written consent)

(Necessary for the performance of the employment contract, compliance with legal obligations and for the legitimate interests of the business.)

• Documentation relating to terms of employment: Up to 6 months after the end of employment (1 year with your written consent)

(Necessary for the performance of the employment contract, compliance with legal obligations and for the legitimate interests of the business.)

• Employee records:  Up to 6 months after the end of employment (1 year with your written consent)

(Necessary for the performance of the employment contract, compliance with legal obligations and for the legitimate interests of the business.)

• Tax & National Insurance, pension and payroll: Up to 7 years after the end of employment

(Necessary for the performance of the employment contract, compliance with legal and tax obligations.)

Automated decision making

No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

Your rights in relation to your information

The law on data protection gives you certain rights in relation to the data we hold on you. These are:  

• the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
• the right of access. You have the right to access the information that we hold on you. To do so, you should make a subject access request
• the right for any inaccuracies to be corrected. If any information that we hold about you is incomplete or inaccurate, you are able to require us to correct it
• the right to have information deleted. If you would like us to stop processing your information, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
• the right to restrict the processing of the data. For example, if you believe the information we hold is incorrect, we will stop processing the information (whilst still holding it) until we have ensured that the information is correct
• the right to portability. You may transfer the data that we hold on you for your own purposes
• the right to object to the inclusion of any information. You have the right to object to the way we use your information where we are using it for our legitimate interests
• the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights. 

Where you have provided consent to our use of your information, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.    

If you wish to exercise any of the rights explained above, please contact:  

Darroch Wickens

[email protected]

BWA People Limited 

2 Long Row, Mersham, Ashford, Kent TN25 7HD

01233 720313

Complaints

You have the right to lodge a complaint with the UK Data Protection Supervisory Authority, whose contact details are available here - https://ico.org.uk/global/cont... 

Cookies

Website / email newsletter users

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. 

You can configure your web browser to refuse cookies, to delete cookies, or to be informed if a cookie is set. You can find out how to do this by clicking "help" on your browser menu. 

To opt out from Google Analytics, please visit: https://tools.google.com/dlpag... To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please view our cookie policy or visit http://www.allaboutcookies.org... You should note that by deleting or blocking cookies, the Website may not function correctly and you may not be able to access certain areas. 

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on this web page. This privacy notice was last updated on 17th July 2018.

How to contact us

Please contact us if you have any questions about our privacy notice or information we hold about you.

The Company’s Data Protection Officer is Darroch Wickens. He can be contacted on:

[email protected] 

BWA People Limited

2 Long Row, Mersham, Ashford, Kent TN25 7HD

01233 720313