STAFF / APPLICANT PRIVACY NOTICE

(How we use your personal information)

This notice explains what information we collect, when we collect it and how we use this. During the course of our activities, we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will process your personal data.

Introduction

The purpose of this staff privacy notice is to explain to you the reasons which we may hold and use your personal data and explain your rights under the current data protection laws.

As your employer we may collect and process personal data relating to you to manage our contract, including pre-contractual negotiations, with you. We are committed to being transparent about how we collect and use your data, and to meeting our data protection obligations with you.

This notice does not form part of your contract of employment or engagement with us. It applies to all our employees, workers, volunteers, apprenticeships and consultants (which includes applicants), regardless of length of service, and may be amended at any time. If any amendments are required in the future, we will notify you as is appropriate.

Glen Oaks Housing Association of: 3 Kilmuir Drive, Arden, Glasgow, G46 8BW

We are registered as a data controller with the Information Commissioner’s Office (‘ICO’) and our registered number is Z5443064.

Where does your personal information come from?

The Association may collect information in several ways which include:

• Personal data which you have provided to us

• Recruitment processes including information obtained from agencies

• Your identification documents you have given us

• Background checks conditional for your engagement with us (if relevant)

• PVG/Disclosure/DVLA checks relating to criminal convictions / offences

• Former employers or other individuals whom you have given us permission to contact to provide us with a reference

• Medical professionals provide us with appropriate health information in order that we can manage any health- related situations that may have an impact on your ability to work with us.

• Membership with professional bodies that confirm membership

• Qualifications/training bodies that provide us information relating to you

• Web browsing history and email exchanges can be routinely monitored for the purposes of maintaining the IT infrastructure

• HMRC

What Information do we collect?

The Association controls and processes a range of information about you. In this privacy notice ‘your personal information’ means your personal data i.e. information about you from

which you can be identified. Your ‘personal information’ does not include data where your identity has been removed (anonymous data). It is really important that the personal

information that we hold and process about you is accurate and up to date. Please keep us informed if your personal information changes during your engagement with us.

This includes:

• Your name, address, and contact details including email address and telephone number, date of birth and gender

• The terms and conditions of your employment or engagement with us

• Details of your qualifications, skills, experience and work history, including start and end dates with previous employers and workplaces

• Information about your remuneration, including entitlement to benefits such as, pay, pension and holidays

• Details of your bank account and national insurance number

• Information about your marital status, next of kin, dependants and emergency contacts

• Information about your nationality and entitlement to work in the UK

• Information about any criminal convictions if relevant for your job.

• Details of your work pattern (days of work and working hours) and attendance at work

• Details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals

• Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence

• Assessments of your performance, including appraisals, performance reviews and ratings, performance improvement plans and related correspondence

• Information about medical or health conditions, including if you have a disability for which the organisation needs to make reasonable adjustments

• Equal opportunities monitoring information including protected characteristics

• CCTV imagery

• Telephone call recordings

The data we hold about you will be kept in your personnel file which is stored securely and access to the files is restricted. The information will only be held for the periods outlined in the Association’s Retention Policy.

What are the legal bases for us processing your personal data

We will only process your personal data on one or more of the following legal bases:

• contract

• consent

• our legitimate interests (including CCTV recordings, telephone call recordings, business planning and resilience, publishing certain information on our website, the operation of our IT systems and next of kin details)

• vital interests

• public interest / official authority

• legal obligation

Processing Special Category Personal Data

Special categories of information means information about your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; health; sex life or sexual orientation; criminal convictions, offences or alleged offences; genetic data; or biometric data for the purposes of uniquely identifying you.

The "special categories" of sensitive personal information referred to above require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information, including in the following situations:

• In limited circumstances, with your explicit written consent.

• Where we need to carry out our legal obligations and in line with our privacy policy.

• Where it is needed in the public interest, such as for equal opportunities monitoring and in line with our Privacy Policy.

• Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Our Obligations as Employer

We will use your particularly sensitive personal information in the following ways:

• We will use information relating to leave of absence, which may include sickness absence or family related leave, 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.

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 interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Employee Monitoring

We will carry out the following monitoring exercises:

• CCTV – images and footage recorded of any person visiting our premises. This is used for staff safety, security and the prevention (detection) of crime. Footage is currently retained for 1 month

• Wi-fi Browsing – Our I.T. provider can monitor web browsing history and email exchanges for the purposes of maintaining the IT infrastructure 

• Phone records of Association mobile users with regards to call history and length of calls. Recordings are retained for 30 days

Where do we keep your data?

Your information will only be processed within the UK where international transfers are authorised by law.

How do we keep your data safe?

When you give us information, we take steps to make sure that your personal information is kept secure and safe. All personal data is process in accordance with Glen Oaks Housing Association’s data protection policies and procedures. Our systems are password protected and all electronic data is stored securely. All paper files are kept in locked cabinets.

How long do we keep your data?

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law and in accordance with our Data Retention Policy and Schedule.

If you do not wish to provide your personal data

You have obligations under your employment contract to provide the organisation with the necessary data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide the Association with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.

Certain information, such as contact details, your right to work in the UK and the payment details, must be provided to enable the Association to enter into a contract of employment with you. If you do not provide other information, this will hinder the Association’s ability to administer the rights and obligations arising as a result of the employment relationship efficiently.

Your Rights

You have the right at any time to request to exercise your data subjects’ rights in relation to the following:

• the right to be informed

• the right to access

• the right to rectification

• the right to object to processing

• rights in relation to automated decision making and profiling

• the right to be forgotten

• the right to data portability

• the rights to restrict processing

Who might my data be shared with, or seen by?

We may disclose your personal data to any of our employees, officers, contractors, insurers, professional advisors, agents, suppliers or subcontractors, selected third parties. Government agencies and regulators and healthcare providers insofar as reasonably necessary, and in accordance with data protection legislation.

We may also disclose your personal data:

• with your consent

• to the extent that we are required to do so by law

• to protect the rights, property and safety of us, our customers, users of our website and other persons

• in connection with any ongoing or prospective proceedings

• if we are investigating a complaint, information may be disclosed to solicitors, independent investigators, including auditors, the Scottish Housing Regulator and other regulatory bodies, whether investigating the complaint or otherwise

• to the purchaser (or prospective purchaser) of any business or asset that we are, or are contemplating, selling;

• to another organisation if we enter into a joint venture or merge with another organisation.

Queries and Complaints

Any questions relating to this notice and our privacy practices should be directed, in the first instance, to go@glenoaks.org.uk or by telephoning 0141 638 0999.

Our Data Protection Officer is provided by RGDP LLP and can be contacted either via 0131 222 3239 or info@rgdp.co.uk

You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:

Telephone: 0303 123 1113

Online: Make a complaint | ICO

The accuracy of your information is important to us; please help us keep our records updated by informing us of any changes to your personal and contact details.

This Privacy Notice was last updated on 9.10.24.