Specific Privacy Section for Our Workforce

This is a specific privacy section which supplements our general privacy information notice which can be viewed here. It applies in addition to all the information in our general privacy information notice.

Our Workforce – by this we mean current and former employees and agency workers. We do not collect more information than we need to fulfil our purposes, this will be slightly different for current and former employees and agency workers, so for each group, we have identified below what we do.

What kind of personal data we hold about our workforce?

We will collect, store, and use a variety of personal data about you, including the following categories of personal information about you:

Current and former employees

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  • Date of birth
  • Gender
  • Marital status and dependents
  • 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
  • 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 memberships)
  • Compensation history
  • Performance information
  • Disciplinary and grievance information
  • CCTV footage and other information obtained through electronic means such as swipe card records.
  • Information about your use of our information and communications systems.
  • Photographs.
  • Distribution driver monitoring records, driver card, tachograph, vehicle location, driver behaviour
  • Video interviews, if these are used
  • Psychometric and testing data

We may also collect, store and use the following "special categories" of more sensitive personal information:

  • Information about your age range, race or ethnicity, religious beliefs, sexual orientation and political opinions
  • Trade union membership
  • Information about your health and any disability, including any medical condition, health and sickness records
  • Genetic information and biometric data
  • Information about criminal convictions and offences

Agency Workers

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  • Date of birth
  • Training and induction records
  • Fitness to work certification and any occupational health records
  • Working records – including rotas, schedules and time sheets
  • Accident and injury records for you (if any)
  • Security and access control history
  • Distribution driver monitoring records, driver card, tachograph, vehicle location, driver behaviour
  • CCTV footage when you attend our sites

How is your personal data collected?

We collect personal information about you 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, credit reference agencies or other background check agencies or from publicly available sources.

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

How we use the personal data we collect about our workforce?

The situations in which we will process your personal information are listed below.

Current and Former Employees

  • For administration purposes
  • Determining the terms on which you work for us
  • Checking you are legally entitled to work in the UK
  • Paying you and, if you are an employee, deducting tax and National Insurance contributions
  • Providing benefits to you
  • Liaising with your pension provider
  • Administering the contract we have entered into with you
  • 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 our 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 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
  • Equal opportunities monitoring

For information, the Warburtons Pensions and Life Assurance Plan ("Scheme”) Trustees give further information about the use of your information when administering your pension in the Scheme’s Data Protection and Privacy Policy which is communicated to you separately.

Agency workers

  • For administration purposes
  • To manage your time working at our site(s)
  • To assess your fitness to work
  • To assess your qualifications for a particular job or task
  • To ensure your working time is recorded and reported to our agency services provider and your recruitment agency

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

What is our lawful basis for processing this personal data about our workforce?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to perform the contract we have entered into with you, or in the case of agency workers, the contract we have entered into for the provision of your agency labour services;
  2. Where we need to comply with a legal obligation, such as our legal obligations as your employer, or in the case of agency workers because we have duties to you when you work on our site (s);
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  4. In some circumstances, we may need your consent to process your personal data, this will be explained to you when required.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest.

We need all the categories of information in the list above (see paragraph) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override this. 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.

Who do we share your personal information with?

We may have to share your data with third parties, including third party service providers and other entities in the group.

We will share your personal information with third parties only where we have a lawful basis to do so.

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities in respect of our workforce are currently carried out by third-party service providers: pension administration, benefits provision and administration, IT services, IT system providers, community grant application system, recruitment services, agency labour service providers, accident and injury management systems and service providers, medical advisers, legal advisers, insurers, other relevant professional advisers, government agencies and other authorities.

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.

Your Employment Terms and Conditions

Where there is a data protection consent clause in your existing terms and conditions of employment, we confirm that we are no longer relying on those clauses to process, collect and use your personal data. This Privacy Notice explains our processing, collection and use of your personal data and in particular the section on lawful basis for processing your personal data is explained in more detail.

This privacy notice does not form part of your terms and conditions of employment.

How long do we keep or use your personal data?

Your personal data is kept and used by us in line with our Data Retention Policy which is available on HR Policies and Procedures database or upon request (see how to contact us section of our general privacy notice).

Changes to this Specific Privacy Section

We reserve the right to update this specific privacy section at any time. This specific privacy section was last updated in May 2018.