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Privacy Notice for Employees

 

Last Modified: February 2023

 

 

Retailors Ltd. and its affiliated companies (“Company”, “we”, “our”, or “us”) are committed to protecting and respecting your privacy. This notice sets out the basis on which any personal data and/or Personal Information (“Personal Information” means any data that can or may be used whether alone or in combination with other information in order to identify you) that you provide to us, or that we otherwise collect, will be processed. This notice does not form part of any contract of employment or other contract to provide services.

 

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Information about you, so that you are aware of how and why we are using such information.

 

For the purpose of this notice, “employees” means direct employees, contractors or consultants engaged by the Company, as well as job candidates, as applicable.

 

 

1.OUR DATA PROTECTION PRINCIPLES

We are committed to ensure that the Personal Information we process about you will be:

  • Used lawfully, fairly and in a transparent way.

  • Collected for specified, explicit and legitimate purposes, and not further processed in a manner that is incompatible with those purposes.

  • Adequate, relevant and limited to what is necessary in relation to those purposes.

  • Accurate and kept up to date.

  • Kept only as long as necessary for those purposes.

  • Kept securely.

 

2.WHY DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect, store and process Personal Information about you for the following purposes:

 

  • Your recruitment as a Company employee.

  • The process of onboarding you as a Company employee.

  • Managing our ongoing relationship and performing our duties towards you as an employee.

  • Complying with legal requirements we are subject to as an employer.

 

 

3.WHAT INFORMATION WE COLLECT ABOUT YOU

 

We collect, store, use and process all or some of the following categories of Personal Information about you:

 

  • Personal details - such as: your name, title, addresses, telephone numbers, personal email addresses, date of birth, gender, marital status and dependants, next of kin and emergency contact information, Identification number, as well as a copy of your ID , passport or driving license when required by applicable law.

  • Financial details - Bank account details, payroll records and tax status information.

  • Information pertaining to your employment terms - salary, annual leave, pension, and benefits

 

information.

  • Data contained in your personnel file - such as start date/leaving date, Location of employment or workplace, compensation\benefits history, performance reviews, and grievances.

  • Information collected for the purposes of your recruitment - 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, such as past employment records, job titles, training records, professional certifications.

  • CCTV - part of our security ecosystem, we may use CCTV systems to monitor physical access, we limit access to the application and database to a need to know basis.

  • Images & Video - while documenting our social life within the company we may take pictures / video and use them internally or externally.

  • Publicly available online information - such as your LinkedIn profile URL or other similar social network.

  • We may also collect, store, use and process the following “special categories” of more sensitive Personal Information:

    • Information about your health - including any medical history and health and sickness records.

    • Information about criminal convictions/ allegations and offences.

 

4.HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

Prior to your employment – we collect Personal Information about employees through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may also collect additional information from third parties including former employers, credit reference agencies or other background check agencies or publicly available resources (such as social networks).

 

During your employment – we will collect Personal Information in the course of job-related activities throughout the period of you working for us.

 

5.HOW DO WE USE YOUR PERSONAL INFORMATION

Most commonly, we will use your Personal Information in the following circumstances:

 

  • To assess your candidacy, and to perform the contract we have entered into with you as an employee – for example:

    • Making a decision about your recruitment, employment or termination.

    • Assessing qualifications for a particular job or task, including decisions about promotions, salary reviews and compensation.

    • Paying you and deducting tax and National Insurance contributions as required by law

    • Conducting performance reviews, managing performance, and determining performance requirements.

 

  • To comply with a legal or regulatory obligation – for example:

 

  • Deducting tax, as well as other deductions required by law or as a result of service you requested.

  • Checking you are legally entitled to work in the country where you are employed by us

  • Liaising with your pension provider, providing information about changes to your employment

 

such as promotions, changing in working hours.

  • In order to comply with our legal and regulatory obligations (e.g. to combat money laundering, terrorist financing, corruption and bribery).

  • Dealing with legal disputes involving you or others, including accidents at work.

 

  • Where it is necessary for our legitimate business purposes and to manage the employment relationship

  • for example:

    • Accounting and auditing.

    • Business management and planning.

    • Education, training and development requirements.

    • To conduct data analytics studies to review and better understand employee retention and attrition rates.

    • Gathering evidence for possible grievance or disciplinary hearings.

    • To ensure network and information security, including preventing unauthorised access to our computers and electronic communications systems and preventing malicious software distribution.

    • Complying with health and safety obligations.

 

Depending on the situation, you may be entitled to refuse or withdraw your consent to our processing of your Personal Information. If you withdraw your consent or 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).

 

We will only use your Personal Information for the purposes for which we collected it. 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.

 

6.HOW DO WE USE SENSITIVE PERSONAL INFORMATION?

 

We will, if necessary, process special categories of Personal Information in the following circumstances:

 

  • Information about your health - We may use particularly sensitive Personal Information about your health in the following ways:

  1. 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.

  2. We will use information about your 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.

  3. We will use information about your health to assist with your enrolment on our appointed benefit provider, as applicable.

  • Information about criminal convictions and offences - 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.

 

  • Your fingerprint – we may use this biometric information in order to document your attendance.

  • Your Consent - In some circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

 
7.SHARING YOUR PERSONAL INFORMATION WITH THIRD PARTIES

Where required by law, where necessary to administer the working relationship with you or where we have another legitimate interest in doing so, we may have to share your data with third parties, including third- party service providers and other entities in the Company group.

 

We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your Personal Information outside of the jurisdiction where you reside and as a result, this information may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions. If we do, you can expect a similar degree of protection in respect of your Personal Information.

 

  • Sharing of Personal Information with other entities in the group -  We  may 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 reorganisation or group restructuring exercise.

 

  • Sharing of Personal Information with relevant internal personnel with a genuine “need-to-know” – for example:

    • The Company management and HR teams, consisting of a limited number of individuals.

    • Individuals performing administrative and IT support functions;

 

  • Sharing of Personal Information with third parties - We may share your Personal Information with other third parties, for example:

    • Recruiters working with us, hiring managers and other interviewers. Often these individuals will be based in the country where the position is based, but in some cases they may be located in other countries;

    • In the context of the possible sale or restructuring of the Company.

 

  • Sharing of Personal Information with Authorized personnel at our service providers – for example:

    • Providers of talent acquisition systems.

    • Providers of HR and payroll management systems.

    • Companies contracted to perform candidate background screenings. These companies may be based in another country and may obtain data from other countries where you have lived, worked or studied, as may be relevant as part of a background check.

    • Pension providers

    • Government Departments

 

  • Law enforcement, governmental authorities and regulators – for example, where legal reporting requirements may exist, or law enforcement agencies or private litigants in response to valid law enforcement process (warrant, subpoena, or court order).

 

All our third-party service providers and other entities in the group are required to take appropriate

 

security measures to protect your Personal Information. We do not allow our third-party service providers to use your Personal Information for their own purposes. We only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

 

Transferring information outside the EU and /or Canada

 

We may need to transfer the Personal Information we collect about you to third parties outside the EEA and/or outside of Canada, in order to perform our contract with you, in which case your Personal Information may be made available to foreign law enforcement authorities under laws applicable in these jurisdictions. We will implement appropriate safeguards and mechanisms to ensure that your Personal Information does receive an adequate level of protection when it is transferred outside of the EEA and/or outside of Canada, including, where applicable, using Standard Contractual Clauses approved by the European Commission.

 

 

8.HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

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 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 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.

 

9.RETAINING YOUR PERSONAL INFORMATION

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 Data Retention Policy. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

In some circumstances we may anonymize 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 of the Company we will retain and securely destroy your Personal Information in accordance with our internal data retention policies.

 

 

10.YOUR RIGHTS

  • 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. We encourage you to keep your Personal Information up to date on all platforms made available to you in the course of your employment.

 

•Your rights in connection with Personal Information

 

Under certain circumstances, by law you have the right to:

 

  1. Access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.

  2. Correction of your Personal Information. This enables you to have any incomplete or inaccurate information we hold about you corrected.

  3. Withdraw your consent to the processing of your Personal Information. This enables you to withdraw your consent to our processing of your Personal Information for some specific purposes, subject to legal and contractual restrictions.

If you are a European Union resident, you may also have the right to:

  1. Erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it.

  2. Object to processing of your Personal Data. 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 Data for direct marketing purposes.

  3. Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

  4. Request the transfer of your Personal Data (Right of portability). This enables you to request to receive your Personal Data in a structured, commonly used and machine-readable format and to transmit those data to another party.

If you wish to exercise any of the aforementioned rights, please contact us through the below details. You also have the right to make a complaint to the applicable supervisory authority for data protection issues.

 

11.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.

 

If you have any questions about this privacy notice, please contact us through the below details.

 

 

12.CONTACT US

 

If you have any questions about this privacy notice or how we handle your Personal Information, please contact us through the following E-mail: HReurope@foxnsp.com

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