Agency Worker & Employee Privacy Notice

Agency Worker & Employee Privacy Notice

As a recruitment business, the company collects and processes personal data relating to agency workers and employees to manage the employment relationship.

We are committed to being transparent about how we collect, use, store, transfer and retain this data and in meeting our data protection obligations.


What information do we collect?

The company collects and processes a range of information about you. This includes

  • your name, address and contact details, including email address and telephone number, date of birth and gender;
  • the terms and conditions of your employment;
  • 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 or insurance cover;
  • details of your bank account and national insurance number;
  • information about your marital status, next of kin, dependants and emergency 
  • information about your nationality and entitlement to work in the UK;
  • information about your criminal record;
  • details of your schedule (days of work and working hours) and attendance at work;
  • 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, performance reviews and ratings, performance improvement plans and related correspondence;
  • information about medical or health conditions, including whether or not you have a disability for which the company needs to make reasonable adjustments; and
  • equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief; 
The company may collect this information in a variety of ways. For example, data might be collected through application forms, CVs or resumes; obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of or during employment (such as benefit nomination forms); from correspondence with you; or through interviews, meetings or other assessments. 
In some cases, the company may collect 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. The company seeks information from third parties with your consent only. 
Data will be stored in a range of different places, including in your personal file, on databases, in the company’s HR management systems and in other IT systems (including the company’s email system). 
Why do we process personal data? 
The company needs to process data to enter into a contract for services if you are an Agency Worker or an employment contract if you are an Employee and to meet its obligations under the contract. For example, it needs to process your data to provide you with a relevant contract, to pay you, to administer benefits etc. 
In some cases, the company needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee’s entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled. 
In other cases, the company has a legitimate interest in processing personal data before, during and after the end of the employment relationship.

Processing personal data allows the company to;

  • run recruitment and promotion processes;
  • maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of individual contractual and statutory rights;
  • operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
  • operate and keep a record of performance and related processes, to plan for career development, and for succession planning and workforce management purposes;
  • operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that individuals are receiving the pay or other benefits to which they are entitled;
  • obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled;
  • operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that the company complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled;
  • ensure effective general HR and business administration;
  • provide references on request for current or former workers;
  • respond to and defend against legal claims; and
  • maintain and promote equality in the workplace. 
Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (such as those in relation to employees with disabilities). Where the company processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, health and criminal records, this is collected with the express consent of individuals, which can be withdrawn at any time. Employees are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

Who has access to data?

Your information will be shared internally, including members of the Paragon Meed team, management, HR and IT staff if access to the data is necessary for performance of their roles.

In the case of Agency Workers, the company also has to share a limited amount of personal data with third party hirers, such as your name, contact details, availability for work and any health conditions for the purposes of duty of care or making reasonable adjustments.

The company may also share your data with third parties in order to obtain pre- employment references from other employers, obtain employment background checks from third-party providers and obtain necessary criminal records checks from the Disclosure and Barring Service.

To fulfil its contract with you, the company also shares your data with service providers and regulatory bodies that process data on its behalf in connection with payroll, HR services, provision of benefits, accountancy and audit etc.

Your data may be transferred to countries outside the European Economic Area (EEA) however where this is the case then safeguards will be put in place to ensure that any such service provider is GDPR compliant or equivalent.

How do we protect your data?

The company takes the security of your data seriously. The company has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees or appointed persons in the legitimate performance of their duties.

All employees are bound by confidentiality and are trained in safe data security.

Where the company engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

How long do we keep data?

The Company will hold your personal data for the duration of your employment. The periods for which your data is held after the end of employment is as follows;

  • 2 years for all personal data and records;
  • 6 years + current for all contractual information, attendance information, 
family friendly and payroll data; and
  • Basic details including name, NI Number, start date, leave date, training 
records and accident/H&S records would be retained indefinitely.

What if you do not provide personal data?

You have some obligations under your contract to provide the company with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith.

You may also have to provide the company with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.

Certain information, such as contact details, your right to work in the UK and payment details, have to be provided to enable the company to enter a contract with you. If you do not provide other information, this will hinder the company’s ability to administer the rights and obligations arising as a result of the relationship efficiently.

Automated decision-making

Employment decisions are not based solely on automated decision-making.

Your rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require the company to change incorrect or incomplete data;
  • require the company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
  • object to the processing of your data where the company is relying on its legitimate interests as the legal ground for processing. 
If you would like to exercise any of these rights, please contact us using the above details. 
If you believe that the company has not complied with your data protection rights, you can complain to the Information Commissioner Office (ICO) however we would like the opportunity to address any concerns and ask that you contact us in the first instance.


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