This privacy notice tells you what to expect us to do with your personal information when you apply to work for us, or when you are employed by us.
Contact details
To contact our Data Processing Officer, email dpo@bradfordcft.org.uk
1. What information we collect and use, and why
Staff recruitment, administration and management
We collect or use the following personal information as part of staff recruitment, employee administration and management:
- Contact details (e.g. name, address, telephone number and 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)
- Marital status
- 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
- Criminal Offence data, including relevant information about criminal activity, allegations, investigations and proceedings
- 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
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
- Religious or philosophical beliefs
- Trade union membership
- Sexual orientation information
- Disability information
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)
- Time spent working (e.g. timesheets, authorised leave forms)
- Expenses, 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
- Trade Union membership
We also collect or use the following special category information for managing salaries and pensions. This information is subject to additional protection due to its sensitive nature:
- Trade union membership
- Health information
Staff health and wellbeing
We collect or use the following personal information for managing staff health and wellbeing:
- General health and wellbeing information
- Occupational health referrals and reports
- Fit notes (e.g. Statement of Fitness for Work from a GP or hospital)
- Return to work forms
- 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)
We also collect or use the following special category information for managing staff health and wellbeing. This information is subject to additional protection due to its sensitive nature:
- Racial or ethnic origin
- Religious or philosophical beliefs
- Health information, including disability
2. Lawful bases and 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. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- 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. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
- Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
- Your right to erasure – You have the right to ask us to delete your personal information. Read more about the right to erasure.
- Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
- Your right to object to processing – You have the right to object to the processing of your personal data. Read more about the right to object to processing.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
3. Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information as part of staff recruitment, administration and management are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- 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.
Our lawful bases for collecting or using personal information as part of managing salaries and pensions are:
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- 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.
Our lawful bases for collecting or using personal information as part of managing staff health and wellbeing are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
4. Where we get personal information from
We collect your information from the following places:
- Directly from you
- Employment agency
- Schools, colleges, universities or other education organisations
- Referees (external or internal)
- Occupational Health and other health providers
- Pension administrators or government departments (e.g. HMRC and DWP)
- Trade Unions
- Staff benefit providers
- Public sources (e.g. LinkedIn or other websites)
- CCTV footage or other recordings
- DBS (Disclosure and Barring Service)
- SWE (Social Work England)
- Police forces
- LADO
- Social Services
- Visa Solicitors (Where relevant for Visa sponsored colleagues)
- Home Office (Where relevant for Visa sponsored colleagues)
5. How long we keep information
We keep your information in line with our retention schedule (Appendix 1).
For further 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.
6. Who we share information with
In some circumstances, we may share information with the following organisations:
- Training suppliers
- HMRC
- Employee benefit schemes
- Health and benefit suppliers
- City of Bradford Metropolitan District Council (CBMDC)
- The Police
- LADO
- Social Services
- The Home Office
- External auditors
- Professional consultants, including solicitors and legal teams
- Referees (in and out)
7. Data processors
We use the following data processors for the following reasons:
| CBMDC payroll | This data processor processes payroll information on the trust’s behalf |
| Tribepad | This data processor stores data on our behalf |
| Civica | This data processor stores employee data on our behalf |
| West Yorkshire Pension Fund | This data processor administers pensions on the Trust’s behalf |
| Spectrum Life | This data processor provides counselling services on the Trust’s behalf |
| UKIM | This data processor provides Occupational Health services on the Trust’s behalf |
| Disclosure and Barring Service | This data processor conducts criminal records checks, including checks of the barred list where applicable to the role |
| Veritau | This data processor provides DPO services to the Trust’s Information and Governance team |
8. Raising a complaint
If you have any concerns about our use of your personal data, please send your complaint to us at dpo@bradfordcft.org.uk. It is important that you take this first step so we can resolve any complaints internally in the first instance. By raising a complaint internally, we are able to work with you to understand the complaint, and work with you to resolve it.
If after raising a complaint with us, you remain unhappy with how we’ve used your data, you can raise a complaint with the ICO. The ICO’s address is:
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