Most of the data we collect about you will be for normal employment reasons. In addition, there’s likely to be some information you give to us voluntarily, for example if you take part in a survey. This section explains the data that we will typically collect about you.
We maintain an employment record containing personal data that we collect and create before, during and, where necessary, after your employment. We may also process other personal data for separate purposes described in this privacy policy.
Data that you give to us
Mandatory information
To employ and pay you, we need certain details from you:
- Name and title
- Date of birth
- Home address
- Phone number
- Email address
- National Insurance Number, if you have one
- Bank details
- A certified copy of your photographic ID (usually your passport)
- Sex (we take this from your passport)
- Nationality
- A certified copy of your work visa, if required
- Occupation
- Industry
- Details about your student loan, if applicable
- Details about your work assignments
- Information about your working situation to help us allocate you the most appropriate tax code
- The P45 your previous employer gave to you (if you have one)
- Details about the recruitment agencies you work with
- Your candidate reference number, if your agency has given you one
You usually give us these details when you complete our registration form, or we may follow up with you later to ask for them.
We normally collect this information directly from you. In some circumstances, we may receive it from your recruitment agency, HMRC or another source described in this policy.
These details are mandatory because without them, we may be unable to employ you, fulfil all of our employment obligations, deduct the correct amount of tax from your pay or provide you with the level of fast, user-friendly service that we aim for.
If anything changes or you spot any mistakes in the data that we hold about you, it’s important that you let us know. We will update our records but may keep an archived copy of your old information too.
For all of the data we’ve covered in this section, our lawful basis for collecting it is contract. This is because it’s necessary in order for us to fulfil our obligations to you.
Learn more:
- How do I update or correct my details?
- Why do you need to know my sex?
- Why do you need to know my title?
Ad hoc information
During your employment, you might provide us with additional data about yourself. Due to the nature of a normal employer/employee relationship, it could include data such as:
- Accident reports
- Expense claims and receipts
- Emails you send us
- Details of your work assignments
- Details about your qualifications and training
- Details about holidays or other breaks from work
- Medical information
- Future/former employers
- Evidence to support statutory benefit applications
If you choose not to provide us with any of these details, it may be impossible for us to meet our obligations to you or to provide you with the service that you’ve asked for.
Depending on why we need the information, our lawful basis will usually be that it is necessary to perform our employment contract with you, to comply with a legal obligation, or to pursue our legitimate interests in administering our employment relationship and business. The relevant basis is explained in each section below.
We encourage you to only share information with us that is relevant for employment purposes, or that you are comfortable sharing conversationally. In data protection law, there’s a list of ‘special category’ data, which is data that is considered to be particularly sensitive. For example, it includes details relating to your health, trade union membership or religion. When you give us ‘special category’ data, the law requires that we can identify both our lawful basis for processing the data and an additional separate condition to cover the fact that it is ‘special category’.
In the event that you disclose sensitive information to us for employment purposes, our additional condition for storing and acting on it is that it’s necessary for carrying out our employment obligations.
If you disclose special-category information to us that is not relevant to your employment or to a service you have asked us to provide, we will avoid recording it where possible. If it is recorded incidentally, we will not use it for an unrelated purpose and will delete or restrict it when it is no longer necessary. Where we need to use special-category information, we will identify an appropriate lawful basis and an additional condition under data-protection law.
Voluntary information
During your employment, you might choose to take part in surveys, polls or competitions that we organise, or contribute photos or comments for articles we’re writing. Or you may answer optional questions on forms that you complete. For example, on our registration form we ask for your Twitter username so that we can follow you and say hello.
Participation in anything like this is always voluntary and we will always explain what we will do with the data you’re giving to us. Our lawful basis for collecting this data is legitimate interests. If you change your mind about allowing us to use data that you submitted voluntarily, you can let us know by emailing hello@key.co.com.
Data we create
To help us manage your employment efficiently and smoothly, we create some data about you:
- We assign you an Employee ID which is a unique identifier that we use to help us manage your employment. We will give you a note of this number. If you leave employment and then re-join in the future, your Employee ID will stay the same.
- We also assign you a payroll number, which is a unique identifier that we use to identify you to HMRC. If you leave and then re-join in the future, you will be assigned a new payroll number for each period of employment.
- We keep notes in our CRM system, e.g. records of conversations we’ve had with you, and may refer to you in emails as we strive to meet our duties as an employer.
- When you first join, we email you a link to your contract of employment, which you can read and sign online. The link contains a unique string of characters that we use to identify you. It’s how we’re able to show you a personalised version of your contract with your name and address on it, and how we know that you’ve signed it.
Our lawful basis for doing these things is contract, because it is necessary in order to fulfil our obligations to you.
- Throughout your employment, we will generate pay advice slips and statutory documentation such as a P60. As your employer, these are legal requirements and so our lawful basis for doing this is legal obligation.
Data we collect from third parties
It’s likely that we will collect data about you from third parties:
- Your recruitment agency will routinely provide us with details about the number of days and hours you work and the agreed daily/hourly rate. We use this information to pay you, so our lawful basis for this is contract.
- HMRC may share information to ensure that we deduct the correct amount of tax, e.g. your tax code. Our lawful basis for this is legal obligation.
- Since it’s likely that your recruitment agency already holds copies of your photographic ID and work visa and would be able to certify them for us, we may ask for your permission to request a copy from them. Our lawful basis for this is contract.
- In limited circumstances, we may review information that has been made publicly available where this is necessary to investigate suspected fraud, protect our legal rights or address a significant employment or safeguarding concern. We will only collect information that is relevant and proportionate to that purpose.
- Our workplace pension scheme is provided by NEST. We exchange relevant employment, earnings and pension-contribution information with NEST so that we can assess eligibility, administer enrolment, deduct contributions and meet our workplace-pension obligations. We can also access relevant information through NEST’s employer portal. You can read NEST’s privacy notice on its website.
You have the right to object to processing based on our legitimate interests. If you object, we will consider your circumstances and stop the processing unless we have compelling legitimate grounds to continue or need the information to establish, exercise or defend a legal claim.