Privacy Notice for Staff and Volunteers, Trustees and Student Placements

What is the purpose of this document?

Missing Link/Next Link/Safe Link is committed to protecting the privacy and security of your personal information. We are a data controller. This means we are responsible for deciding how we hold and use personal information about you. This notice explains to you what decisions we have taken in relation to that information.

We are registered on the Information Commissioner’s Office Register; registration number Z3246008 and act as the Data Controller when processing your data. Our designated Data Protection Appointed Person is Bally Kandola, Director of Resources, who can be contacted at dataprotection@missinglinkhousing.co.uk

Missing Link/Next Link/Safe Link’s registered office is at Part 2nd Floor, Embassy House, Queens Avenue, Clifton, Bristol BS8 1SB and we are a Housing Association with charitable status, registered under the Co-operative and Community Benefit Societies Act (2014). Register No. 24218R.

This Privacy Notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

General Data Protection Principles

In collecting and processing your personal information, we will comply with the data protection law in force at the time. This requires that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

Information That We Collect

We collect personal information about our employees/volunteers through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, other agencies and the Disclosure and Barring Service.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

We handle and store your personal information in line with data protection laws.

Information that we may collect might include:

  • Name and contact details so we can keep in touch with you about your support
  • Date of Birth
  • Equalities Data – information, for example, your ethnicity
  • Health/Medical information/Sick Notes (where relevant)
  • Next of Kin
  • Bank Details (where necessary)
  • National Insurance Number/Passport Number/Driving Licence/Vehicle Insurance (where relevant)
  • Photograph (where necessary)
  • Criminal Record details (where necessary)

How We Use Your Personal Data

We will use your information for the following purposes:

  • To ensure correct and legal information under contract of employment and with legislative bodies such as HMRC.
  • To enable payment of salary/wages/NI/tax/pension contributions/expenses
  • To ensure employees have access to effective recourse if they have any concerns about their employment
  • To take appropriate action in the event of any conduct or performance concerns
  • To maintain appropriate levels of conduct and performance

Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), the legal basis we rely on for processing personal information for general purposes are:

  • Necessary for the performance of a contract to which the data subject is a party
  • Necessary for compliance with a legal obligation
  • Necessary for the legitimate interests of the organisation

Where we use your personal information to pursue the legitimate interests of the business, we will only do so provided your interests and fundamental rights do not override those interests.

Some of the personal data we process can be more sensitive in nature and therefore requires a higher level of protection. The GDPR refers to the processing of this data as ‘special categories of personal data’. This means personal data about an individual’s:

  • race;
  • ethnic origin;
  • political opinions;
  • religious or philosophical beliefs;
  • trade union membership;
  • genetic data;
  • biometric data (where this is used for identification purposes);
  • health data;
  • sex life; or
  • sexual orientation.

Personal data can include information relating to criminal convictions and offences. This also requires a higher level of protection.

Under the General Data Protection Regulation (GDPR), the legal basis we rely on for processing sensitive data information are:

  • Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law
  • Processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent
  • Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Sharing information with third parties

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.

We 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 we have another legitimate interest in doing so.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data Security

We have 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, we limit 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 on our instructions and they are subject to a duty of confidentiality.

We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including password security, encryptions, restricted access, IT authentication, firewalls and anti-virus/malware.

Staff who access your data have had data protection training to make sure your information is handled sensitively and securely.

We have 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 we are legally required to do so.

Data Retention

Missing Link/Next Link/Safe Link will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and we have strict review and retention policies in place to meet these obligations.

A copy of our Data Retention and Erasure Policy is available on request.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your Rights

Under certain circumstances, the law grants you specific rights. These are summarised below. Please note that your rights may be limited and subject to restrictions in certain situations:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us 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 we 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 we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us 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 erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the person responsible for data protection: Bally Kandola, Director of Resources: dataprotection@missinglinkhousing.co.uk

Transfers Outside the EU

Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data. Missing Link/Next Link/Safe Link does not transfer or store any personal data outside the EU.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Lodging A Complaint

Missing Link/Next Link/Safe Link only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws.

If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to complain to the person responsible for Data Protection:

Bally Kandola, Director of Resources: dataprotection@missinglinkhousing.co.uk

If you are not satisfied with how your complaint has been dealt with, you have the right to lodge a complaint to the supervisory authority:  Information Commissioners Office https://ico.org.uk/