Privacy Policy
Site Editor
Trans-web Ltd., Sarena House, Vulcan Street, Oldham, OL1 4LQ, UK.
Copyright
This website and its content is copyright of Trans-web Limited – © Trans-web Ltd. 2018. All rights reserved.
Any redistribution or reproduction of part or all of the contents in any form is prohibited other than the following:
- you may print or download to a local hard disk extracts for your personal and non-commercial use only
- you may copy the content to individual third parties for their personal use, but only if you acknowledge the website as the source of the material
You may not, except with our express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it on any other website or another form of electronic retrieval system.
Warning regarding contents
Despite all the care taken to preserve the integrity of the information and documents put online, the presence of an error cannot be totally excluded. The responsibility of Trans-web Ltd cannot be engaged because of these fortuitous errors.
Linking to the Website
You may link to our website, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.
You must not establish a link from any website that is not owned by you.
The Website must not be framed on any other site. We reserve the right to withdraw linking permission without notice. The website from which you are linking must comply in all respects with the content standards set out in our acceptable use policy.
If you wish to make any use of material on the Website other than that set out above, please address your request to info@trans-web.co.uk
Viruses, hacking and other offences
The user agrees that material downloaded or otherwise accessed through the use of the Website is obtained entirely at the user’s own risk and that the user will be entirely responsible for any resulting damage to software or computer systems and/or any resulting loss of data, even if such loss and damage was reasonably foreseeable and Trans-web had been advised of the possibility of the same.
You must not misuse the Website by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to the Website, the server on which the Website is stored or any server, computer or database connected to the Website. You must not attack the Website via a denial-of-service attack or a distributed denial-of-service attack.
By breaching the provisions, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use the Website will cease immediately.
We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of the Website or to your downloading of any material posted on them, or on any website linked to them.
Protection of personal data
No personal information is collected without your knowledge. No personal information is disclosed to third parties.
Tracking cookies and advertisements
The user is informed that during his visits to the site, cookies may be automatically installed via his browser.
A cookie is a set of data that does not directly identify the user, but is used to record information relating to the navigation of it on the site. More information on cookies and how they are used can be found here.
Google Analytics
This site uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze the use of the site by its users. The data generated by the cookie about your use of the website (including your IP address) will be transmitted and stored by Google on servers located in the United States. Google will use this information for the purpose of evaluating your use of the site, compiling reports on website activity for its publisher and providing other services relating to website activity and use of the site. Google may disclose such data to third parties in the event of a legal obligation or where such third parties process such data on Google’s behalf, including but not limited to the publisher of this site. Google will not cross your IP address with any other data held by Google. You can disable the use of cookies by selecting the appropriate settings from your browser. However, such disabling may prevent the use of certain features of this site. By using this website, you expressly consent to the processing of your personal data by Google under the conditions and for the purposes described above. You can disable the use of cookies by selecting the appropriate settings from your browser. By using this website, you expressly consent to the processing of your personal data by Google under the conditions and for the purposes described above.
Disable cookies and configure your Internet browser
You can choose to disable cookies. Your browser can also be set to notify you of the cookies that are stored on your computer and ask you to accept them or not. You can accept or refuse cookies on a case-by-case basis or refuse them systematically.
We remind you that the setting may change your access to our content and services requiring the use of cookies. If your browser is configured to refuse all cookies, you will not be able to enjoy some of our services.
- INTERNET EXPLORER: In Internet Explorer, click the Tools button, and then click Internet Options. On the General tab, under Browsing History, click Settings. Click the Show Files button.
- FIREFOX: Go to the Tools tab of the browser and select the Options menu In the window that appears, choose Privacy and click on Show cookies.
- SAFARI: In your browser, choose Edit menu> Preferences. Click Security. Click Show Cookies.
- GOOGLE CHROME: Click the Tools menu icon. Select Options. Click the Advanced Options tab and go to the Privacy section. Click the Show Cookies button.
General Data Protection Regulation (GDPR) and the Data Protection Bill (to repeal and replace the Data Protection Act, 1998)
Privacy Notice – Commercial Activities
Data Controller
Trans-Web Limited Sarena House, Vulcan Street, Oldham, OL1 4LQ Person with responsibility for data protection compliance within the Company Keith Miller, Sales Director, who can be contacted via email at |
What information does Trans-Web collect?
- Trans-Web Limited (Trans-Web, the Company) collects and processes personal data and information as an integral part of it’s wide-ranging commercial and business development activities. This Notice tells you how Trans-Web manages any personal information it holds about you.
- Trans-Web is committed to meeting its data protection obligations. If you decide to give us personal information as part of establishing or maintaining a commercial and/or business relationship, this information will be held and processed by Trans-Web in accordance with the General Data Protection Regulation.
As part of this, the Company recognises the proper obligations upon it to protect your privacy. The Company is also committed to being transparent about how it uses the personal information collected as part of its commercial and business development activities.
- Trans-Web collects and processes a range of information about you. Together with your areas of business activity and interest, the personal information collected will include your name, your Company and/or employer’s name, your job title, your business address, and your business contact email address, telephone numbers, and social media contact details.
- Trans-Web collects this information in a variety of ways. You may have chosen to give us the personal information because you wanted Trans-Web to process a business request for you.
These types of request often include, for example, providing you with information about the Company’s products or services, or to provide a business proposal and/or quotation, or to place an order or commission a contracted production assignment. You may have given us your personal information by direct contact with the Company, initiated by you. Alternatively, you may have given us your personal information as part of a business meeting or as part of the wide range of professional conference, promotional, networking and trade body activities that Trans-Web participates in.
Trans-Web does not generally collect personal information about you from third parties. Where this does occur, Trans-Web will only do this with your prior consent. Trans-Web will also let you know if personal information about you is collected from other open or public sources, including the internet and social media platforms. The Company does not use your information to create a personal profile about you.
- Personal information about you will be stored in a number of different places. These include the Company’s commercial contact database, the Company’s marketing and sales database, the Company’s email system and the mobile telephones provided to and used by Company employees.
Why does Trans-Web process personal information?
- Trans-Web offers a range of specialised business products and commercial services which, if you choose to use them, will require information from you in order for the Company to fulfil your requirements. The Company collects, controls, and processes personal information for a number of purposes, including –
- To process information as part of entering into a commercial contract with you and/or your employing organisation, and to meet its obligations under any such contract, including payment and related financial transactions
- To process and perform the delivery of products and services you have requested, and including the supply of business-related information about Trans-Web and the Company’s range of products and services
- To help the Company to create and deliver content about products and services that will be most relevant to your business needs
- To alert you to new products and services and other business-related information, including up-dated delivery times and pricing information
- To make on-going contact between you and Trans-Web easier, by not requiring you to enter your personal information more than once
- To enable the Company to undertake standard business analysis, including charting business development trends to inform future marketing and sales plans, and to inform the future development of the Company’s products and services
This commercial and business-related information relates to the products and services available directly from Trans-Web and also the Company’s associated business partners.
- Trans-Web recognises and respects that personal information will only be used for the purposes for which it was supplied. The Company also recognises that you may not wish to be contacted again after the original reason for establishing contact has been fulfilled.
You can opt-out of receiving information from Trans-Web at any time by contacting Keith Miller, Sales Director, via email at keith.miller@trans-web.co.uk You can opt-out from receiving all information from the Company, or from receiving specific categories of information designated by you.
Who has access to the information?
- Your personal information will be shared internally with Company employed colleagues where access to the data is necessary for the performance of their job roles and the delivery of products and services to you.
- Trans-Web may disclose your personal information to others in connection with any legal or prospective legal proceedings, and/or in order to establish, exercise or defend the Company’s legal rights and/or obligations.
- Trans-Web will not, without your express prior consent, provide your personal information to any third parties for the purpose of direct marketing.
- Trans-Web will not normally transfer your personal information outside the European Economic Area (EEA).
In any circumstances where this becomes necessary, the information will only be transferred with your express prior permission. This will most commonly be in circumstances where your employing Company is operating in a country outside the EEA. In all circumstances the information will be controlled and processed in accordance with the provisions of this Privacy Notice.
How does Trans-Web protect data?
- Trans-Web takes very seriously the security of the personal data and information it controls and processes for commercial and business-related purposes.
The Company takes all reasonable technical and organisational precautions and measures to prevent loss, accidental destruction, misuse, alteration, or disclosure of your personal information. These measures include use of a secure database, together with internal policies and controls to protect personal data. These internal controls also ensure that access to personal information is restricted, and cannot be accessed other than by properly authorised persons in the proper performance of their duties with Trans-Web.
All Company employees are properly briefed about the responsibility to keep your personal information secure.
Data transmission over the internet is inherently insecure. Trans-Web cannot guarantee the security of data sent over the internet.
- Trans-Web does not buy or sell personal information.
- Where the Company engages third party associates to process personal information on its behalf, such parties operate in accordance with the appropriate Trans-Web control policies and arrangements. Additionally, the contract for service with such associates includes express duties of confidentiality and non-disclosure, together with an obligation to implement appropriate technical and organisational measures to ensure the security of personal data and information.
For how long does Trans-Web keep personal information?
- Trans-Web will hold your personal information for the duration of your commercial and business-related contact with the Company.
- Trans-Web will hold your personal information after the end of your commercial and business-related contact with the Company for 6 years, in accordance with the UK Limitation Act. In the case of financial information, the retention period will be 6 years from the end of the financial year in which the transaction was made.
After this period the information will be archived or safely destroyed.
Your individual rights and responsibilities
- As a data subject, you have a number of rights. You can –
- Access and obtain a copy of your personal information on request
- Require the Company to change incorrect or incomplete personal information
- Require the Company to delete or stop processing your personal information eg where the information is no longer necessary for the purposes of processing
- Object to the processing of your personal information where the Company is relying on its legitimate interests as the legal ground for processing
- If you want to exercise any of these rights, please contact Keith Miller, Sales Director, via email to miller@trans-web.co.uk Keith is the person with responsibility for data protection compliance within Trans-Web.
- The Company recognises that the personal information it holds about you is likely to change over time. For example, you may change your employer, or your job role and contact details may change.
Trans-Web will, as part of its normal good housekeeping, periodically undertake appropriate data up-dating and cleansing operations. However, if the personal information the Company holds about you needs to be corrected or updated, it is always helpful if you are able to promptly notify required changes via email to keith.miller@trans-web.co.uk
- If you believe that Trans-Web has not complied with your data protection rights, you can complain to the Information Commissioner.
General Data Protection Regulation (GDPR) and the Data Protection Bill (to repeal and replace the Data Protection Act, 1998)
Privacy Notice – Job Applicant
Data Controller
Trans-Web Limited Sarena House, Vulcan Street, Oldham, OL1 4LQ Person with responsibility for data protection compliance within the Company Keith Miller, Sales Director, who can be contacted via email at |
What information does Trans-Web collect?
- As part of its employee recruitment process, Trans-Web Limited (Trans-Web, the Company) collects and processes personal data relating to job applicants. Trans-Web is committed to being transparent about how it collects and uses the personal data of job applicants, and to meet its data protection obligations.
- Trans-Web collects and processes a range of personal information about you. This includes –
- Your name, home address, contact details (including email address and telephone numbers), date of birth, and gender
- Details of your qualifications, skills, experience, and employment history including start and end dates of previous employments
- Additional information that you may include in any covering letter to accompany your CV or application form
- Information about your current level of remuneration, and including information about your entitlement to related benefits and benefit entitlements
- Whether or not you have a disability for which Trans-Web needs to make reasonable adjustments during the recruitment process
- Information about your entitlement to work in the UK
- Information about any applicable criminal record, in relation to a very limited number of specifically designated jobs within the Company
- Trans-Web collects this information in a variety of ways. For example, data might be collected through your CV or completed application form, any covering letter, or obtained from your passport or other identity documents (eg driving licence), or collected through interviews or other forms of assessment.
Trans-Web may also collect personal data about you from third parties. Trans-Web will only do this with your prior consent, and as part of the Company making a job offer to you. Most commonly, this will include employment references supplied to Trans-Web by your former employers.
- Personal data about you will be stored in a number of different places. These include your application file, the Trans-Web HR information system, designated recruitment platforms, and other Company IT systems (eg DropBox, Cloud-based storage), and the Company’s email system.
Why does Trans-Web process your personal data?
- Trans-Web needs to process data to take steps at your request prior to entering into an employment or related contract with you. It may also need to process your data to subsequently enter into an employment contract with you.
- In some cases Trans-Web needs to process personal data to ensure it is complying with its legal obligations. For example, it is required to check that you are entitled to work in the UK before employment starts.
- In other cases, Trans-Web has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Trans-Web to –
- Manage external recruitment and internal promotion processes
- Assess and confirm a candidate’s overall suitability for employment
- Decide to whom to offer a job or a promotion
- Make reasonable adjustments for candidates who have a disability, as part of its obligations, and to exercise specific rights in relation to employment
- Respond to, and defend legal claims
- For some roles, Trans-Web is obliged to seek information about criminal convictions and offences. Where Trans-Web seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment. In these circumstances, Trans-Web will advise you beforehand if this requirement applies to the job you are applying for.
- Importantly, Trans-Web will not use your data for any other purpose other than the recruitment opportunity for which you have applied.
In circumstances where Trans-Web wishes to use your data in relation to other and/or future recruitment opportunities, it will only do this with your express written prior consent, which you are free to withdraw at any time.
Who has access to your personal data?
- Your information may be shared internally, including with the Trans-Web recruitment team, interviewers directly involved in the recruitment and assessment process, the Company’s HR Adviser and other Managers with a direct interest in the appointment being made.
- Trans-Web will not share your data with third parties, other than if your application is successful and it makes you an offer of employment. In these circumstances, Trans-Web will share your data with your former employers for the purpose of obtaining employment references for you, together with any required criminal records checks from the Disclosure and Barring Service. In these circumstances the data will be subject to appropriate confidentiality and non-disclosure arrangements.
- Trans-Web will not transfer your data to countries outside the European Economic Area (EEA).
How does Trans-Web protect your personal data?
- Trans-Web takes the security of HR-related data seriously. The Company uses internal policies and controls to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed other than by employees in the proper performance of their duties with Trans-Web.
- Within Trans-Web, external employment recruitment and internal promotion decisions are not based solely on automated decision-making.
For how long does Trans-Web keep your personal data?
- If your application for employment is unsuccessful, Trans-Web will hold your data on file for 12 months after the end of the recruitment process. This is based on the retention period recommended by the Chartered Institute of Personnel and Development (CIPD).
- If you agree to allow Trans-Web to keep your personal data on file for the purpose of being considered for other or future employment opportunities with the Company, Trans-Web will hold your data on file for a further 12 month period. At the end of that period, or if you withdraw your consent for the retention of your personal data during the extended period, your data is permanently deleted and put beyond use.
- If your application for employment is successful, your personal data gathered during the recruitment process will be transferred to your employment file, and retained during your employment with Trans-Web. The periods for which your personal data will be held are set out in the Trans-Web Employment Privacy Notice.
Your individual rights and responsibilities
- As a job applicant, you are under no statutory or contractual obligation to provide personal data to Trans-Web during the recruitment process. Notwithstanding this, if you do not provide the requested information, Trans-Web may not be able to process your application either properly, fully, or at all.
- As a data subject, you have a number of rights. You can –
- Access and obtain a copy of your personal data on request
- Require Trans-Web to change incorrect or incomplete personal data
- Require Trans-Web to delete or stop processing your personal data eg where the personal data is no longer necessary for the purposes of processing
- Object to the processing of your personal data where Trans-Web is relying on its legitimate interests as the legal ground for processing
- If you want to exercise any of these rights, please contact Keith Miller, Sales Director, Trans-Web, via email at miller@trans-web.co.uk
- If you believe that Trans-Web has not complied with your data protection rights, you can complain to the Information Commissioner.
General Data Protection Regulation (GDPR) and the Data Protection Bill
Employment Policy Statement
Purpose and Scope
- This Policy Statement sets out Trans-Web Limited’s (Trans-Web, the Company) approach to HR-related data protection. It includes the Company’s commitment to data protection, and individual rights and obligations in relation to personal data.
The Policy Statement applies to the personal data, referred to as HR-related personal data of employees, workers, apprentices, trainees, contract for service providers, and former employees. Trans-Web maintains separate Privacy Notices in relation to job applicants, and other personal data processed for business purposes.
- Trans-Web is committed to being transparent about how it collects and uses the personal data of employees of the Company, and to meet its data protection obligations.
- Trans-Web has designated Keith Miller, Sales Director, as the person with responsibility for data protection compliance. Questions about this Policy Statement, or requests for further information should be directed to Keith, who can be contacted via email at miller@trans-web.co.uk
- Trans-Web will provide special briefings to all employees about their data protection responsibilities. This will include coverage as part of the new employee induction programme, and periodic briefings as part of the Company’s internal communication arrangements.
Individuals whose job roles require regular access to personal data, or who are responsible for implementing this Policy Statement or responding to subject access request, will receive additional training to help them understand their duties and obligations, and how to comply with them.
Trans-Web’s data protection principles
- Trans-Web processes HR-related personal data in accordance with the following data protection principles –
- It processes personal data in a lawful, fair, and transparent manner
- It collects personal data only for specified, explicit, and legitimate purposes
- It processes personal data only where it is adequate, relevant, and limited to what is necessary for the purposes of processing
- It keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay
- It keeps personal data only for the period necessary for processing
- It maintains appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and also accidental loss, destruction, or damage
- Using Privacy Notices, Trans-Web tells individuals about the legal basis and reasons for processing their personal data, and how it uses such data. The Privacy Notices will also set how personal data gathered during employment or engagement is held, together with the periods of time that the Company retains HR-related personal data.
Trans-Web will promptly update HR-related personal data where an individual advises that the relevant information about them has changed or is inaccurate.
Importantly, where Trans-Web processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with relevant additional safeguards as set out in the GDPR and the Data Protection Bill.
- In accordance with the requirements of the GDPR, Trans-Web maintains a record of its processing activities in respect of HR-related personal data.
Individual rights
- As a data subject, an individual has the right to make a subject access request. To make a subject access request, the individual should send the request via email to Keith Miller, Sales Director, Trans-Web, at miller@trans-web.co.uk
In some cases Trans-Web may need to ask the individual for proof of identification before the request can be processed. In such cases Trans-Web will properly inform the individual and advise the type(s) of proof of identity needed.
- Trans-Web will normally respond to a subject access request within one month from the date it is received. The Company will write to the individual within one month of receiving the original request to advise if the response time will be extended to the maximum three months, together with an explanation for the permissible reason for the extended response period.
- In response to a subject access request, Trans-Web will tell the individual –
- Whether or not the individual’s data is processed and if so why, the categories of personal data concerned, and the source of the data if it is not collected from the same individual
- To whom the individual’s data is or may be disclosed, including to recipients outside the European Economic Area (EEA) and the safeguards that apply to such transfers
- For how long the individual’s data is stored
- The individual’s rights to rectification or erasure of data, or to restrict or object to processing
- The individual’s right to complain to the Information Commissioner if they think Trans-Web has failed to comply with their data protection rights
- Whether or not Trans-Web carries out automated decision-making and the logic involved in any such decision-making
- Trans-Web will provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless the individual agrees otherwise.
If the individual wants additional copies, Trans-Web will charge a fee based on the administrative cost of providing the additional copies.
- If the subject access request is manifestly unfounded or excessive, Trans-Web will not be obliged to comply with it. In these circumstances, the Company will notify the individual accordingly, including whether or not Trans-Web will respond to the request.
Alternatively, and in light of the particular circumstances, Trans-Web may decide to respond subject to payment by the individual of a fee that will be based on the administrative cost of responding to the request.
- Trans-Web will comply with all other rights that individuals have in relation to their personal data. These include the rights to –
- rectify inaccurate data
- stop processing or erase data that is no longer necessary for the purposes of processing
- stop processing or erase data if the individual’s interests override Trans-Web’s legitimate grounds for processing data (where this is the reason for processing data)
- stop processing or erase data if processing is unlawful
- stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override Trans-Web’s legitimate grounds for processing data
To exercise any of these rights, the individual should send their request via email to Keith Miller, Sales Director, Trans-Web, at keith.miller@trans-web.co.uk
Individual responsibilities
- Individuals are responsible for helping Trans-Web to keep their personal data up to date. Individuals should notify the Company if any personal data provided to Trans-Web changes eg home address, bank details, etc.
- Individuals may have access to the personal data of other individuals in the course of their employment or engagement with Trans-Web. Where this applies, the Company requires such individuals to help it to meet its data protection obligations.
- Individuals who have access to personal data are required –
- To access only data that they have authority to access, and only for authorised purposes
- Not to disclose personal data to individuals, whether inside or outside Trans-Web, who have appropriate authorisation
- To keep personal data secure, properly using all control and security arrangements
- Not to remove personal data in any form or using any devices from Trans-Web premises without authorisation and without adopting appropriate additional security arrangements
- Not to store personal data on personal devices or in other insecure ways (eg local computer drives) that are used for work purposes
Failure to observe these requirements may amount to a disciplinary offence, which will be dealt with in accordance with the Trans-Web disciplinary procedure. Significant or deliberate breaches of this Policy Statement (eg accessing personal data without a legitimate reason to do so and the appropriate authorisation) may constitute gross misconduct and could lead to dismissal without notice.
Data Security
- Trans-Web takes the security of HR-related data seriously. The Company uses internal policies and controls to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed other than by employees in the proper performance of their duties with Trans-Web.
Trans-Web will not transfer HR-related personal data to countries outside the EEA.
- Where the Company engages third parties to process personal data on its behalf, such parties operate in accordance with the appropriate Trans-Web control policies and arrangements, together with a duty of confidentiality and an obligation to implement appropriate technical and organisational measures to ensure the security of data.
- Some of the processing that Trans-Web carries out may result in risks to privacy. Where processing would result in a high risk to individual’s rights and freedoms, Trans-Web will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals, and the measures that can be put in place to mitigate the identified risks.
Data Breaches
- Trans-Web will record all data breaches, regardless of their effect or assessed impact.
- If Trans-Web discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, the Company will report it to the Information Commissioner within 72 hours of discovery.
- If the data breach is likely to result in a high risk to the rights and freedoms of individuals, Trans-Web will tell all such affected individuals that there has been a breach. Trans-Web will also provide the affected individuals with information about its likely consequences and the mitigation measures it has taken.
General Data Protection Regulation (GDPR) and the Data Protection Bill (to repeal and replace the Data Protection Act, 1998)
Privacy Notice – Employment
Data Controller
Trans-Web Limited Sarena House, Vulcan Street, Oldham, OL1 4LQ Person with responsibility for data protection compliance within the Company Keith Miller, Sales Director, who can be contacted via email at |
What information does Trans-Web collect?
- Trans-Web Limited (Trans-Web, the Company) collects and processes personal data relating to its employees to manage the employment relationship. Trans-Web is committed to being transparent about how it collects and uses the personal data of employees, and to meet its data protection obligations.
- Trans-Web collects and processes a range of information about you. This includes –
- Your name, home address, contact details (including email address and telephone numbers), date of birth, and gender
- The terms and conditions that apply to your employment with the Company
- Details of your qualifications, skills, experience
- Details of your employment history with the Company, and also the start and end dates of previous employments
- Information about your remuneration, and including information about your entitlement to related benefits eg pension
- Details of the bank account as nominated by you
- Details of your National Insurance (NI) Number
- Information about your marital status, next of kin, dependants, and emergency contacts
- Information about any applicable Court Orders, Child Support Agency Attachment of Earnings orders, etc
- Information about your nationality and entitlement to work in the UK
- Information about any applicable criminal record
- Information about your working hours and working pattern with the Company
- Details about your punctuality and attendance at work with the Company
- Details of periods of holiday taken by you, and also including any sickness absence, family leave, other authorised absences, and the associated reasons
- Details of any applicable disciplinary or grievance procedures in which you have been directly involved, including any warnings issued to you, together with related correspondence
- Assessments of your work performance, including probationary reviews, appraisals, performance reviews and any associated ratings, any applicable performance improvement plans, together with related correspondence
- Information about medical or health conditions, including whether or not you have a disability that may require the Company to consider making any applicable reasonable adjustments
- Trans-Web collects this information in a variety of ways.
For example, data might be collected through your CV or completed application form, obtained from your passport or other identity documents (eg driving licence), from forms completed by you at the start of, and throughout, your employment with the Company (eg pension benefit nomination forms), from interviews, meetings or other assessments conducted during your employment with the Company, and from employment-related correspondence with you.
The Company may also collect personal data about you from third parties, but Trans-Web will only do this with your prior consent. For example, this will include employment references supplied to the Company by your former employers. It might also include information from employment background check providers, information from criminal records checks permitted by law, and information from credit reference agencies.
- Personal data about you will be stored in a number of different places. These include your personal employment file, the Company’s general employment-related files, Trans-Web’s HR information system and other Company IT systems (eg DropBox, Cloud storage), and the Company’s email system and mobile telephones.
Why does Trans-Web process personal data?
- Trans-Web needs to process data to enter into an employment contract with you. It also needs to meet its obligations to you under your employment contract. For example, it needs to provide you with an employment contract, to pay you in accordance with your employment contract, and to administer employment-related benefits like your pension.
- In some cases, Trans-Web needs to process personal data to ensure it is complying with its legal obligations. For example, it is required to check that you are entitled to work in the UK. The Company also has to deduct all applicable taxes, to comply with health and safety laws, and to enable every employee to take the periods of holiday that they are entitled to.
- In other cases, Trans-Web has a legitimate interest in processing personal data before, during, and after the end of the employment relationship. Processing employee data allows Trans-Web to –
- Manage external recruitment and internal promotion processes
- Maintain accurate and up-to-date employment records, including records of contractual and statutory rights and entitlements
- Maintain accurate and up-to-date contact details, including details of who to contact in an emergency or incident/accident at work
- Maintain appropriate records of employee relations issues, to ensure the maintenance of acceptable conduct in the workplace
- Keep records of employee performance, to support career development and related workforce planning processes
- Keep a record of absence and associated procedures, to support effective workforce management and to ensure that employees receive the correct pay and other related employment benefits
- Obtain occupational health advice, to ensure the Company fulfils its obligations under health and safety law, and, as appropriate, to individuals with disabilities
- Keep a record of other types of leave (eg maternity, paternity, parental, etc) to allow effective workforce management, to ensure that the Company complies with all contractual entitlements and statutory rights, and to ensure that employees receive the correct pay and other related employment benefits
- Ensure effective general HR and employment-related business administration
- Provide employment references on request, and respond to mortgage enquiries, tenancy/credit/rental requests for current or former employees
- Respond to any legitimate statutory disclosure demands (eg HMRC) or other legal claims
- Some special categories of personal data, such as information about health or medical conditions, is processed by Trans-Web to enable the Company to fulfil its employment law obligations eg health and safety, disability, etc
Where Trans-Web processes other categories of personal data, such as information about ethnic origin, sexual orientation, or religion or belief, etc, this is done only where it is required to fulfil specific employment rights, and is only collected with the express consent of the employee, which can be withdrawn at any time.
Who has access to the data?
- Your information may be shared internally, including with your Manager, the Management Team and Directors, HR, Health & Safety, and Payroll colleagues, and IT colleagues where access to the data is necessary for the performance of their job roles.
- Trans-Web shares your data with third parties in order to obtain pre-employment references from other employers, and, where required, to obtain necessary criminal records checks from the Disclosure and Barring Service. In these circumstances the data will be subject to appropriate confidentiality and non-disclosure arrangements.
- Trans-Web also shares your data with third parties that process data on its behalf. These include the Company’s Group Headquarters, and the Company’s accountant, payroll, pension, IT, HR, and occupational health service providers, each for the provision of services required to deliver your entitlements and rights under your Contract of Employment.
- Trans-Web will not transfer your data to countries outside the European Economic Area (EEA).
How does Trans-Web protect data?
- Trans-Web takes the security of HR-related data seriously. The Company uses internal policies and controls to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed other than by employees in the proper performance of their duties with Trans-Web.
- Within Trans-Web, employment decisions are not based solely on automated decision-making.
- Where the Company engages third parties to process personal data on its behalf, such parties operate in accordance with the appropriate Trans-Web control policies and arrangements, together with a duty of confidentiality, non-disclosure, and an obligation to implement appropriate technical and organisational measures to ensure the security of data.
For how long does Trans-Web keep data?
- Trans-Web will hold your personal data for the duration of your employment.
- Trans-Web will hold your personal data after the end of your employment with the Company for the following retention periods –
- Any applicable regulating statutory periods eg 3 years for accident reports, income tax and NI returns, statutory maternity pay records; 6
years for salary records; and 40 years for prescribed medical records
- Any recognised best practice guidance where there is no definitive statutory requirement eg The UK Limitation Act’s 6-year limit in relation to contractual claims; 6 years after employment ceases for employment records; 12 years for pension scheme and pensioner records; and permanently for Trust Deeds, Rules, and Minutes
Your individual rights and responsibilities
- As a data subject, you have a number of rights. You can –
- Access and obtain a copy of your personal data on request
- Require the Company to change incorrect or incomplete personal data
- Require the Company to delete or stop processing your personal data eg where the personal data is no longer necessary for the purposes of processing
- Object to the processing of your personal data where the Company is relying on its legitimate interests as the legal ground for processing
- If you want to exercise any of these rights, please contact Keith Miller, Sales Director, Trans-Web, via email to miller@trans-Web.co.uk
- If you believe that Trans-Web has not complied with your data protection rights, you can complain to the Information Commissioner.
- You have some obligations under your employment contract to provide Trans-Web with data and information. You may have to provide the Company with data in order to exercise your statutory rights eg statutory holiday and other leave entitlements. You are also required to report absences from work, information about any incidents/accidents/emergencies at work, and information about disciplinary and other matters under the implied duty of good faith.
You are responsible for helping Trans-Web to keep your personal data up to date. You should notify the Company if any personal data provided by you to Trans-Web changes eg home address, bank details, etc.
Some categories of personal data and information have to be provided to enable Trans-Web to enter a contract of employment with you. These types of information include your contact details, your right to work in the UK, your payment details etc. If you do not provide other types of required information it will hinder Trans-Web’s ability to effectively and efficiently administer its obligations and your rights and entitlements arising as a result of the employment relationship. Failing to provide the required personal data or information may mean that you are unable to exercise your statutory rights.