Zeetta Networks Ltd (the Company) is committed to protecting the privacy and security of your personal information.
This document describes how we collect and use personal information about you during and after your working relationship with us, under the General Data Protection Regulation (GDPR).
It applies to all employees, workers and contractors.
The Company is a “data controller”. This means that it is responsible for deciding how to hold and use personal information about you.
The Company is required under data protection legislation to notify you of the information contained in this document.
This document applies to current and former employees, workers and contractors.
This notice does not form part of any contract of employment or other contracts to provide services.
The Company may update this document at any time.
You must read this document, together with any other privacy notices provided on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why the Company is using such information.
Data Protection Principles
The Company must comply with data protection legislation.
This says that the personal information the Company holds about you must be
- Used fairly and lawfully – Transparency through Privacy Notices;
- Collected only for valid purposes that the Company has clearly explained to you and not used in any way that is incompatible with those purposes;
- Adequate, Relevant and Not Excessive to the purposes the Company has told you about and limited only to those purposes;
- Accurate and kept up to date;
- Retained only as long as necessary for the purposes the Company has told you about;
- Kept securely and appropriately;
- Compliant with the rights of the data subjects;
- Not transferred outside of European Economic Area (EEA), unless adequately protected.
Information we hold about you
Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection, these include
- Political views;
- Religion, spiritual or philosophical beliefs;
- Biometric data for ID purposes;
- Health data;
- Sex life data;
- Sexual orientation;
- Genetic data.
Information that will be collected
The Company will 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;
- 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 (only if appropriate);
- 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 membership (when appropriate);
- Compensation history;
- Performance information;
- Disciplinary and grievance information;
- CCTV footage and other information obtained through electronic means such as swipecard records that may be held by the building management company;
- Information about your use of our information and communications systems;
Information that may be collected
The Company 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;
- We do not currently hold Genetic information or biometric data however this may change in the future;
- Information about criminal convictions and offences.
The Company may use the information you have given us to send appropriate gifts or cards if there is a significant event.
The Company also hold next of kin details should there be an emergency. By providing this information you are confirming you have their consent to do this.
Collection of Personal Information
The Company collects personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from employment agencies or background check providers.
The Company may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.
The Company will collect additional personal information in the course of job-related activities throughout the period of your work.
Using the information about you
The Company will only use your personal information where current legislation permits its use.
Most commonly, the Company will use your personal information in the following circumstances
- Where the Company needs to perform the contract entered into with you;
- Where the Company needs to comply with legal obligations;
- Where it is necessary for the Company’s legitimate interests (or those of a third party) and your interests and rights do not override those interests.
The Company may also use your personal information in the following rarer situations
- Where the Company needs to protect your, or someone else’s, interests;
- Where it is needed in the public interest or for official purposes.
Situations in which we will use your personal information
The Company uses the categories of information in the list above to execute your employment contract and comply with legislative obligations.
In some cases, the Company may use your personal information to pursue its legitimate interests or those of third parties, provided your interests and fundamental rights do not override those interests.
The most common situations in which the Company will process your personal information are listed below
- Deciding your recruitment or appointment;
- Determining the terms on which you work for us;
- Checking if you are legally entitled to work in the UK;
- Paying you and, if you are an employee, deducting tax and National Insurance contributions;
- Providing the following benefits to you: Stock Options and Medical Insurance;
Liaising with your pension provider;
- Administering the contract we have entered into with you;
- Company 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 the 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 the Company information and communication systems to ensure compliance with IT policies;
- To ensure network and information security, including preventing unauthorised access to the Company 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 the Company’s use of your personal information.
Failure to provide personal information
If you fail to provide certain information when requested, the Company may not be able to perform the contract entered into with you (such as paying you or providing a benefit), or the Company may be prevented from complying with legal obligations (such as ensuring health and safety of workers).
Change of purpose
The Company will only use your personal information for the purposes for which it is collected unless the Company reasonably considers that it needs to be used for another reason and that reason is compatible with the original purpose.
If the Company needs to use your personal information for an unrelated purpose, it will notify you and explain the legal basis which allows the use of the data.
Please note that the Company may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
”Special categories” of particularly sensitive personal information require higher levels of protection.
The Company needs to have further justification for collecting, storing and using this type of personal information. The Company may process special categories of personal information in the following circumstances
- With your explicit written consent;
- Where the Company needs to carry out legal obligations in line with data protection;
- Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme, and the use is in line with our data protection policy;
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards;
- Less commonly, the Company may process this type of information where it is needed in relation to legal claims or where it is needed to protect your, or someone else’s, interests and you are not capable of giving your consent, or where you have already made the information public. The Company may also process such information about workers or former workers in the course of legitimate business activities whilst retaining appropriate safeguards.
Our obligations as an employer
The Company will use your personal information in the following ways
- relating to leaves of absence, which may include sickness absence or family-related leaves, to comply with employment and other laws;
- relating to your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, provide appropriate workplace adjustments, monitor and manage sickness absence and administer benefits;
- for monitoring and reporting about your race or national or ethnic origin, religious, philosophical or moral beliefs, or sexual life or sexual orientation, to ensure meaningful equal opportunity as required by legislation;
- to provide Medical Insurance if you have opted into this benefit.
The Company does not need your consent to use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law.
In limited circumstances, the Company may approach you for your written consent to allow the processing of certain data. If the Company does so, you will be provided with full details of the information that is needed and the reason it is needed, so that you can consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from the Company.
Information about criminal convictions
The Company may only use information relating to criminal convictions where the law permits. This will usually be where such processing is necessary to carry out the Company’s obligations and will be completed in line with our data protection policy.
Less commonly, the Company may use information relating to criminal convictions where it is necessary for, or in relation to, legal claims, where it is necessary to protect your, or someone else’s, interests and you are not capable of giving your consent, or where you have already made the information public.
The Company may also process such information about workers or former workers in the course of legitimate business activities with the appropriate safeguards.
The Company envisages that it will hold information about criminal convictions. The Company will only collect information about criminal convictions if it is appropriate given the nature of the role and where it is legally able to do so. Where appropriate, the Company will collect information about criminal convictions as part of the recruitment process or when notified of such information directly by you in the course of your working for us.
The Company are allowed to use your personal information in this way to carry out its obligations as an employer as per the terms and conditions of your employment contract.
Automated Decision Making
Automated decision-making takes place when an electronic system uses personal information to decide without human intervention. We are allowed to use automated decision-making in the following circumstances
- Where we have notified you of the decision and given you 21 days to request a reconsideration;
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights;
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights;
- If we make an automated decision based on any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights;
- You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless we have a lawful basis for doing so and we have notified you;
- We do not envisage that any decisions will be taken about you using automated means, however, we will notify you in writing if this position changes.
The Company may have to share your data with third parties, including third-party service providers and other entities in the group.
The Company will require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU with appropriate safeguards in place.
If the Company does share your data, you can expect a similar degree of protection in respect of your personal information as to that already provided.
Sharing Personal Information with third parties
The Company will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where there is another legitimate interest in doing so. The following considerations will be undertaken when data is shared
- Third-party service providers processing my personal information where ”Third parties” include third-party service providers (including contractors and designated agents) and other entities within our group for activities of: payroll, pension administration, benefits provision and administration, IT services, travel bookings, and training;
- Security of my information with third-party service providers and other entities where all 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 legislation and are using your personal data for their own purposes and are processing your personal data for specified purposes and in accordance with our instructions;
- Sharing my personal information with other entities in the company group where your personal information is shared with other entities in the Company’s group as part of regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data;
- Other third parties for example in the context of the possible sale or restructuring of the business or sharing your personal information with a regulator to comply with the law.
Transferring information outside the EU
The Company does not currently transfer personal information collected about you outside the European Union (EU) to perform its contract with you.
If this should change the Company will ensure there is an adequacy decision by the European Commission in respect of the information meaning that the country OR countries to which the transfer of your data is planned are deemed to provide an adequate level of protection for your personal information.
The Company has put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information as instructed by the Company and where they have agreed to treat the information confidentially and to keep it secure.
The Company has put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, the Company limits access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information to undertake the Company instructions and they are subject to a duty of confidentiality.
The Company has 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 legally required to do so.
The Company will only retain your personal information for as long as necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Details of retention periods for different aspects of your personal information are available in the Company data retention policy which is available upon request. To determine the appropriate retention period for personal data, the Company considers legislative requirements as well as 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 the Company processes your personal data and whether it can achieve those purposes through other means.
In some circumstances, the Company may anonymise your personal information so that it can no longer be associated with you, in which case it may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company the Company will retain and securely destroy your personal information in accordance with our data retention policy and applicable laws and regulations.
Rights of access, correction, erasure and restriction
It is important that the personal information the Company holds about you is accurate and current.
It is your duty to update the Company when your personal information changes during your working relationship with it.
You have certain rights in connection to personal information held by the Company. Under certain circumstances, by law, you have the right to
- Request access to your personal information (commonly known as a “data subject access request”) to receive a copy of the personal information the Company holds about you and to check that the Company is lawfully processing it;
- Request correction of the personal information that is held about you, enabling you to have any incomplete or inaccurate information held about you corrected;
- Request the erasure of your personal information, to delete or remove personal information where there is no good reason for the Company continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
- Object to processing of your personal information where the Company are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where the Company are processing your personal information for direct marketing purposes;
- Request the restriction of processing of your personal information. This enables you to ask the Company to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it;
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request the erasure of your personal information, object to the processing of your personal data or request that the Company transfer a copy of your personal information to another party, please send your request to the Company in writing.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, the Company may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, the Company may refuse to comply with the request in such circumstances.
Information required from you
The Company may need to request specific information from you to help confirm your identity and ensure your right to access the information or to exercise any of your other rights. This is part of the security measures used to ensure that personal information is not disclosed to any person that has no right to receive it.
Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Company in writing. Once the Company has received notification that you have withdrawn your consent, it will no longer process your information for the purpose or purposes you originally agreed to, unless it has a legitimate basis for doing so in law.
Data Protection Officer
The Company has appointed a data protection officer (DPO) to oversee compliance with this policy. If you have any questions about this policy or how your personal information is handled, please contact the DPO.
In the event that you have an unsolvable dispute with the Company about the retention and use of your data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Changes to this Privacy Notice
The Company reserves the right to update this policy at any time and will notify you after any substantial updates. The Company may also notify you in other ways from time to time about the processing of your personal information.