Privacy Policy for Employees

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Privacy statement for employees

Key points:

  • Why do we use your data? We typically use your personal information for purposes related to your employment relationship with Ramsay.
  • We use your sensitive data: In performing our role as your employer, Ramsay may use information about your health, racial and ethnic origin, sexual orientation, religion and membership of a trade union.
  • Sharing data: We may share your data with third parties, including third-party service providers and other entities in the group.
  • Security: We respect the security of your data and treat it in accordance with the law.
  • International transfer: We may transfer your personal information outside the EU and, if we do, you can expect a similar degree of protection in respect of your personal information.

What is the purpose of this privacy statement?

Under data protection legislation, Ramsay is required to explain to our employees why we collect information about you, how we intend to use that information and whether we will share your information with anyone else.

This statement applies to all current and former employees, workers and contractors.

This statement does not form part of any contract of employment or other contract to provide services. We may update this statement at any time.

It is important that you read this statement so that you know how and why we use information about you. It is also important that you inform us of any changes to your personal information during your working relationship with us so that the information which we hold is accurate and current.

Who are we?

We are Ramsay Health Care UK Operations Limited, a company registered in England and Wales under company number 1532937 and with our registered office at Tower 42, Level 18, 25 Old Broad Street, London, EC2N 1HQ.

Ramsay is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you.

Our data protection officer

Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.

If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to dataprotectionofficer@ramsayhealth.co.uk.

Why are we collecting your information?

The information that you provide to us is required in order for us to provide you with our basic services under your contract of employment with us. Without this information, we will not be able to employee you.

In some instances, we may use information about you in a way which is not necessary in order for us to employ you but are related to your employment (such as the conduct of staff surveys, measuring equality in the workplace, complying with our legal obligations, etc).

Types of personal information we use

We are collecting information about you which is relevant to your employment. This includes:

  • personal details (such as name, date of birth, gender, marital status, national insurance number);
  • contact details (such as your address, personal telephone number and personal email address);
  • confirmation of your identity (such as a copy of your driving licence);
  • recruitment information (such as copies of right to work documents, references and other information included in a CV or cover letter or as part of the application process);
  • information about your family and others (such as dependants, next of kin and emergency contact numbers);
  • information about your remuneration (such as bank account details, payroll records, tax status information, salary history, pension and benefits);
  • information about your employment with us (such as start date, location of employment / workplace);
  • information about your previous employment (such as job titles, work history, working hours, training records, professional memberships, salary / compensation history);
  • your performance with us (such as appraisal information, colleague and customer feedback, etc);
  • disciplinary and grievance information;
  • security information (such as CCTV footage, swipecard information, etc);
  • information about your use of our information and communications systems;
  • photographs of you

Special categories of personal data

Some of the information which we collect may be special categories of personal data (also called sensitive personal data). Special categories of personal data require a higher level of protection. The special categories of personal data about you which we may collect include:

  • 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;
  • information about criminal convictions and offences.

Source of your personal information

The above information which we collect about you will be obtained through a variety of sources which include:

  • from you directly as part of the recruitment process, including through any psychometric evaluation or skill test;
  • from third parties as part of the recruitment process (such as employment agencies, background check providers, former employers, credit reference agencies);
  • information obtained about you in the course of job-related activities throughout the period of you working for us.

What we do with your information

We use the types of personal data which we have listed above for the following purposes:

  • The recruitment process (such as making a decision about your recruitment or appointment; determining the terms on which you work for us; checking you are legally entitled to work in the UK);
  • Monitoring performance (such as conducting performance reviews; managing performance and determining performance requirements; considering education, training and development requirements; assessing qualifications for a particular job or task, including decisions about promotions);
  • Payment and salary related activities (such as making payments to you, deducting tax and National Insurance contributions, liaising with your pension provider; making decisions about salary reviews and compensation);
  • Providing benefits to you;
  • Day to day employment activities (such as administering the contract we have entered into with you, business management and planning, including accounting and auditing);
  • Grievance, disciplinary or legal disputes (such as gathering evidence for possible grievance or disciplinary hearings; dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work);
  • Determining your continued employment / engagement (such as making decisions about your continued employment or engagement, making arrangements for the termination of our working relationship);
  • Monitoring your health (such as ascertaining your fitness to work, managing sickness absence, complying with health and safety obligations);
  • Monitor your use of our information and communication systems (to ensure compliance with our IT policies; to ensure network and information security, including preventing unauthorised access to our 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);
  • To comply with our legal obligations such as to prevent fraud and equal opportunities monitoring.

How we use your sensitive information

Some of the information which we collect will be special categories of personal data (also called sensitive personal data), such as information about your ethnic background or your health. We will use your particularly sensitive personal information in the following ways:

  • We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws;
  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits;
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting;
  • We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.

How we use information about criminal convictions

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.

What may happen if you do not provide your personal information?

If you refuse 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).

Complying with data protection law

We will comply with data protection law. At the heart of data protection laws are the "data protection principles" which say that the personal information we hold about you must be:

  • used lawfully, fairly and in a transparent way;
  • collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  • relevant to the purposes we have told you about and limited only to those purposes;
  • accurate and kept up to date;
  • kept only as long as necessary for the purposes we have told you about;
  • kept securely.

What is our lawful basis for using your information?

In accordance with the data protection laws, we need a "lawful basis" for collecting and using information about you. There are a variety of different legal bases for using personal data which are set out in the data protection laws.

The lawful bases on which we rely in order to use the information which we collect about you for the purposes set out in this statement will be:

  • using your information in this way is necessary for us to perform the contract between us and you in order to take steps at your request prior to entering into the contract;
  • using your information is necessary for us to comply with legal and regulatory obligations to which we are subject;
  • using your information pursuant to our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • you have given us your consent to use your information for a particular purpose;
  • we need to use your personal information to protect your interests (or someone else’s interests) in a life or death situation;
  • we need to use your personal information in the public interest.

Special categories of personal data

”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. The lawful basis on which we rely in order to use your special categories of personal data which we collect about you will be:

  • it is necessary in order for us to comply with our legal obligations in our role as your employer;
  • you have provided your explicit consent to our use of your information;
  • it is needed in the public interest (such as equal opportunities monitoring, in relation to our occupational pension scheme);
  • less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your vital interests (or someone else’s vital interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information in the course of legitimate business activities with the appropriate safeguards.

Criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We may also process such information in the course of legitimate business activities with the appropriate safeguards.

Sharing your information

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.

Which third-party service providers process my personal information?

”Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers:

  • payroll;
  • pension administration;
  • benefits provision and administration;
  • IT services;
  • job applicant tracking system;
  • risk management system

How secure is my information with third-party service providers and other entities in our group?

All our 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 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.

When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business re organisation or group restructuring exercise, for system maintenance support and hosting of data.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Transferring information outside the EU

We may on rare occasions transfer the personal information we collect about you to our parent company in Australia for administrative and reporting purposes.

We have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

If you require further information about these protective measures, you can request it from the Data Protection Officer at dataprotectionofficer@ramsayhealth.co.uk

Security of your information

We have 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 on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

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. Details of these measures may be obtained from your HR manager.

Can we use your information for any other purpose?

We typically will only use your personal information for the purposes for which we collect it. In limited circumstances we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.

We may use your personal information without your knowledge or consent where such use is required or permitted by law.

Storing your information and deleting it

We 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. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the Intranet. To determine the appropriate retention period for personal data, we consider 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 we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy.

  • 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 your HR manager. Alternatively, you can make a request to our Data Protection Officer (contact details provided at the beginning of this privacy notice).

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 your HR manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Right to complain to the ICO

You also have the right to complain to the Information Commissioner's Office (the "ICO") if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Changes to this privacy statement

We reserve the right to update this privacy statement at any time, and we will provide you with a new privacy statement 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.

Request to not be subject to automatic decisions

We do not use profiling and/or make decisions about you based on wholly automated processing of your personal information.