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Applicant / Employee Privacy Policy

 

Contact details

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Email: scp@socrates.org.uk

 

What information we collect and use, and why

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Staff recruitment, administration and management

 

We collect or use the following personal information as part of staff recruitment, administration and management:

 

  • Contact details (e.g. name, address, telephone number or personal email address)

  • Date of birth

  • National Insurance number

  • Gender

  • Photographs (e..g staff ID card)

  • Copies of passports or other photo ID

  • Copies of proof of address documents (e.g. bank statements or bills)

  • Next of kin or emergency contact details

  • Employment history (e.g. job application, employment references or secondary employment)

  • Education history (e.g. qualifications)

  • Right to work information

  • Details of any criminal convictions (e.g. DBS checks)

  • Performance records (e.g. reviews, disciplinary records, complaints or disciplinary action)

  • Training history and development needs

  • Monitoring employees’ IT use

  • CCTV footage or other recordings

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We also collect or use the following special category information for staff recruitment, administration and management. This information is subject to additional protection due to its sensitive nature:

 

  • Racial or ethnic origin

  • Salaries and pensions

 

We collect or use the following personal information as part of managing salaries and pensions:

 

  • Job role and employment contract (e.g. start and leave dates, salary, changes to employment contract or working patterns)

  • Expense, overtime or other payments claimed

  • Leave (e.g. sick leave, holidays or special leave)

  • Maternity, paternity, shared parental and adoption leave and pay

  • Pension details

  • Bank account details

  • Payroll records

  • Tax status

 

Staff health and wellbeing

 

We collect or use the following personal information for managing staff health and wellbeing:

 

  • General health and wellbeing information

  • Sick leave forms or fit notes (e.g. Statement of Fitness for Work from a GP or hospital)

  • Accident at work records

  • Access needs or reasonable adjustments

  • Protected Characteristics (as defined by the Equality Act and s.75 of the Northern Ireland Act for the purpose of equal opportunities monitoring)

 

Data protection rights

 

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. Which lawful basis we rely on may affect your data protection rights which are set out in the section below.

 

Your right of access

 

You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. We must provide a copy of the information free of charge. We can only charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive. We may also charge a reasonable fee to comply with requests for further copies of the same information. This does not mean that we can charge for all subsequent access requests. Any fee will be limited to the reasonable administrative costs of complying with the request (for example, staff time, copying, printing and postage). Information must be provided without delay and at the latest within one month of receipt.

 

We can extend the period of compliance by a further two months where requests are complex or numerous. If this is the case, we must inform you within one month of the receipt of the request and explain why the extension is necessary.

 

Where requests are manifestly unfounded or excessive because they are repetitive, we can:

 

  • charge a reasonable fee taking into account the administrative costs of providing the information; or

  • refuse to respond.

 

If we refuse to respond to a request, we must explain why to you, informing you of your right to complain to the Information Commissioner’s Office (ICO) without undue delay and at the latest within one month.

 

Your right to rectification

 

You have the right to ask us to correct personal information you think is inaccurate or incomplete.

 

We will take reasonable steps to verify the accuracy of the information and, where appropriate, correct or complete it without undue delay.

 

Your right to erasure

 

In general you have the right to ask us to delete your personal information. However, where we are required to retain your personal information to comply with the law or in line with our retention periods, we may not be able to delete it during that period. Please see the section “How long we keep information” for more detail.

 

Your right to restriction of processing

 

In general, data protection law gives individuals the right to ask for the restriction of processing of their personal information in certain circumstances.

 

However, we only collect and process personal data where we have a lawful basis to do so. For staff recruitment, administration and management, we rely on legal obligation and legitimate interests as our lawful bases.

 

Because this processing is necessary to meet those obligations and to operate our service safely, lawfully and effectively, we will not be able to restrict the processing of your personal information where doing so would prevent us from meeting those purposes.

 

If you do not agree to the collection and use of your personal information as described in this notice, we will not be able to progress your application or employ you.

 

Your right to object to processing

 

In general, data protection law gives individuals the right to object to the processing of their personal information in certain circumstances.

 

However, for staff recruitment, administration and management, we rely on legal obligation and legitimate interests as our lawful bases. This processing is necessary to operate our service safely, lawfully and effectively.

 

Where an objection would prevent us from meeting these purposes, we will not be able to comply with the request.

 

If you do not agree to the collection and use of your personal information as described in this notice, we will not be able to progress your application or employ you.

 

Your right to data portability

 

In general, data protection law gives individuals the right to request that their personal information be transferred to another organisation, or to them, in certain circumstances.

 

This right only applies where processing is based on consent or contract and is carried out by automated means. As we do not rely on consent or contract as our lawful basis for staff recruitment, administration and management, this right does not apply to the personal data we process for these purposes.

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To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

 

Lawful bases for collecting and using your personal information

 

Staff recruitment, administration and management

 

Legal obligation

 

We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

 

Legitimate interests

 

We’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

 

Our legitimate interests are:

 

  • To ensure a safe working environment for employees

  • To provide a high-quality psychological service

  • To ensure all needs of all employees are identified and acted upon consistently

  • To ensure that all employees are treated in accordance with Socrates policies

 

In the absence of those benefits it is considered there would be a chaotic working environment, lack of transparency, mistakes, risk of harm; all of which impact on the service in terms of professionalism and morale with the high risk of significant harm to the business which then impacts on the safety of clients and the duty of care to our employees.

 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

 

Collecting or using personal information as part of managing salaries and pensions
 
Legal obligation

 

We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

 

Collecting or using personal information as part of managing staff health and wellbeing
 
Legal obligation

 

We have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

 

Where we get personal information from

 

We collect your information from the following places:

 

  • Directly from you

  • Referees (external or internal)

  • Pension administrators or government departments (eg HMRC and DWP)

  • Public sources (eg LinkedIn or other websites)

  • CCTV footage or other recordings

 

How long we keep information

 

For non-clinical employees we will retain your personal data both during your employment and for six years following the termination of your employment (except for pension information which is retained for 75 years).

 

For clinical employees, Socrates will retain your personal data (except for pension information which is retained for 75 years) for as long as it retains the client records for clients you have treated, which is as follows:

 

  • Adult health records: 8 years from discharge or when the client was last seen.

  • Children health records: 26th birthday.

 

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

 

Who we share information with

 

In some circumstances, we may share information with the following organisations:

 

  • HMRC

 

How to complain

 

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

 

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

 

The ICO’s address:          

 

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Helpline number: 0303 123 1113

 

Website: https://www.ico.org.uk/make-a-complaint

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