Privacy Notice Events

Servoca Secure Solutions Ltd

Worker and contractor GDPR privacy notice (Events)

Privacy notice

This notice explains how Servoca Secure Solutions (referred to in this notice as we, us or our) collects and uses information about existing and former workers and contractors for engagement related purposes.

This notice covers the following:

What is personal data?

How do we collect personal data?

What information do we collect?

How do we use your information?

What is the legal basis that permits us to use your information?

What happens if you do not provide information that we request?

How do we share your information?

How do we keep your information secure?

For how long do we keep your information?

Your rights in relation to your information

Complaints

The Table at the end of this notice provides an overview of the data that we collect, the purposes for which we use that data, the legal basis which permits us to use your information and the rights that you have in relation to your information.

This notice does not form part of any contract of employment or other contract to provide services. We keep this privacy notice up to date, so if there are any changes to the way in which your personal data is used this privacy notice will be updated and we will notify you of the changes.

Contact details

Our contact details are as follows:

Address: Servoca Secure Solutions, Solar House, 1-9 Romford Road, Stratford, London E15 4LJ

Contact e-mail: events.info@servoca.com

We have appointed a data protection officer who has responsibility for advising us on our data protection obligations. You can contact the data protection officer using the following details:

sss.gdpr@servoca.com 

 

What is personal data?

Personal data is any information that tells us something about you. This could include information such as your name, contact details, date of birth, medical information and bank account details.

 

How do we collect personal data?

We collect personal data about you from various sources including:

  • from you when you contact us directly through the application and recruitment process or during your engagement;
  • from other people when we check references or background checks are conducted – if we do this we will inform you during the recruitment process of the checks that are carried out;
  • Word of mouth
  • Job boards and
  • we also collect information about job-related activities through the course of your engagement with us.

 

What information do we collect?        

We collect the following categories of information about you:

  • Personal contact details such as name, title, address, telephone number and personal email addresses
  • Date of birth
  • Gender
  • Equal opportunities monitoring information such as ethnicity and disability
  • Next of kin and emergency contact information
  • National insurance number
  • Bank account details, payroll records and tax status information
  • Salary, annual leave and auto enrolment pension information
  • Dates of assignments
  • Location of assignments
  • Recruitment information (including copes of right to work documentation, references, and other information in your CV or application form or otherwise provided as part of the application process)
  • Assignment records (including pay rates, working hours and training records)
  • Hourly rates
  • CCTV footage and other information obtained through electronic means such as swipecard records
  • Photographs
  • Information about your health, including any medical condition, health and sickness records
  • Information about criminal convictions and offences committed by you

 

 

How do we use your information?

We use your information for the following purposes:

  • To make decisions about your recruitment and engagement
  • To determine the terms on which you provide services for us
  • To check you are legally entitled to work in the UK
  • To ensure you are correctly paid and the correct tax deductions and national insurance contributions are made, via a Payroll Company
  • To liaise with the Company pension provider (if required)
  • To administer the contract we have with you
  • For business management and planning purposes, including auditing
  • To assess your suitability and availability for a particular assignment
  • To make arrangements for the termination of our working relationship
  • For training
  • To deal with legal disputes involving you or other employees, workers or contractors, including accidents at work
  • To ascertain your fitness for work
  • To manage sickness absence
  • To comply with health and safety obligations
  • To prevent fraud
  • To carry out equal opportunities monitoring
  • For insurance purposes

 

What is the legal basis that permits us to use your information?

Under data protection legislation we are only permitted to use your personal data if we have a legal basis for doing so as set out in the data protection legislation. The legal bases we rely upon to offer these services to you are:

  • Consent
  • Where we need information to perform the contract we have entered into with you.
  • Where we need to comply with a legal obligation.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

In more limited circumstances we may also rely on the following legal bases:

  • Where we need to protect your interests (or someone else's interests).
  • Where it is needed in the public interest or for official purposes.

The Table at the end of this notice provides more detail about the information that we use, the legal basis that we rely on in each case and your rights.

Some information is classified as "special" data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs and trade union membership. This information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal data. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data. We may process special categories of personal data and criminal conviction information in the following circumstances:

  • In limited circumstances with your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.
  • We will use information about your physical and mental health or disability status to comply with our legal obligations, including 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.
  • We will use information about your race or ethnic origin to ensure meaningful equal opportunity monitoring and reporting – the legal basis of this processing is that it is in the public interests to carry out diversity monitoring.

 

What happens if you do not provide information that we request?

We need some of your personal data in order to perform our contract with you. For example, we need to know your bank details so that we can arrange for you to get paid for the work you perform. We also need some information so that we can comply with our legal obligations. For example, we need information about your health and fitness to work to comply with our health and safety obligations.

Where information is needed for these purposes if you do not provide it we will not be able to perform our contract with you and may not be able to offer you or continue with your engagement.

 

How do we share your information?

We share your personal data in the following ways:

  • With other entities in our group as part of our regular reporting activities on company performance, for system maintenance support and hosting of data.
  • Where we use third party services providers who process personal data on our behalf in order to provide services to us. This includes:
  • IT systems providers
  • Payroll provider
  • Auditors
  • Clients where you are deployed to provide stewarding services
  • Training provider/assessments
  • SIA
  • Police
  • Local Authority
  • We will share your personal data with regulators, including certified auditors, where we are required to do so to comply with our regulatory obligations.
  • We will share your personal data with third parties where we are required to do so by law. For example, we are required to provide tax-related information to HMRC.
  • If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy notice.

Where we share your personal data with third parties we ensure that we have appropriate measures in place to safeguard your personal data and to ensure that it is solely used for legitimate purposes in line with this privacy notice.

 

How do we keep your information secure?

All data is held on secure servers housed in a private suite within a Level(3) data centre. Access to the suite requires RFID access to the building, biometric fingerprint access to the floor the suite is on, and then a key code combination to access the private suite.

 

The internet breakout is secured using a Cisco firewall and we have Cyber Essentials accreditation for network security. All data is held on secure SAN nodes with RAID 10 redundancy, and data is accessible by authorised individuals only based on Active Directory and implemented windows security permissions.

 

All virtual servers are fully backed up nightly to a separate server within the private suite via Veeam software, and following this the backup is then replicated to a secure server housed at our Head Office in Stratford. External network access is limited to authorised users only, running Cisco AnyConnect VPN software via the Cisco ASA. All external access if via Windows RDP server access, with features such as printing to devices outside of the company network disabled.

 

We use the full Trend Micro Smart Protection Complete Suite, with all updates immediately deployed and enforced by our central Control Centre. All urgent windows security updates are automatically downloaded and deployed overnight by the Windows Server Update Service to ensure all servers and client machines are fully protected against latest threats. Practises employed to help secure company data include (but are not limited to):

 

Access to all data restricted to only authorised users.

  • Endpoint encryption in place for portable media ( including laptops)
  • USB write blocking to prevent data being copied to personal drives
  • Blocking of all web based email and data storage websites
  • All users are required to change their password every 30 days
  • All user passwords must meet minimum security requirements
  • All machines auto lock after 10 minutes of inactivity to prevent unauthorised access to unattended machines

 

All hardware, backups, and data links are fully monitored 24/7 using PRTG Enterprise Console.

We will ensure access to personal data is restricted to employees working within our group on a need to know basis.  Training will be provided to any employees working within the group who need access to your personal data to ensure it is secured at all times.

 

 

For how long do we keep your information?

As a general rule we keep your personal data for the duration of your engagement and for a period of 5 years after your engagement ends in line with HMRC and British Standard requirements. However, where we have statutory obligations to keep personal data for a longer period or where we may need your information for a longer period in case of a legal claim, then the retention period may be longer.

 

Your rights in relation to your information

You have a number of rights in relation to your personal data, these include the right to:

  • be informed about how we use your personal data;
  • obtain access to your personal data that we hold;
  • request that your personal data is corrected if you believe it is incorrect, incomplete or inaccurate;
  • request that we erase your personal data in the following circumstances:
  • if we are continuing to process personal data beyond the period when it is necessary to do so for the purpose for which it was originally collected;
  • if we are relying on consent as the legal basis for processing and you withdraw consent;
  • if we are relying on legitimate interest as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing;
  • if the personal data has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation);
  • if it is necessary to delete the personal data to comply with a legal obligation;
  • ask us to restrict our data processing activities where you consider that:
  • personal data is inaccurate;
  • our processing of your personal data is unlawful ;
  • where we no longer need the personal data but you require us to keep it to enable you to establish, exercise or defend a legal claim;
  • where you have raised an objection to our use of your personal data;
  • request a copy of certain personal data that you have provided to us in a commonly used electronic format. This right relates to personal data that you have provided to us that we need in order to perform our agreement with you and personal data where we are relying on consent to process your personal data;
  • object to our processing of your personal data where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal data;
  • not be subject to automated decisions which produce legal effects or which could have a similarly significant effect on you.

If you would like to exercise any of your rights or find out more, please contact sss.gdpr@servoca.com The Table at the end of this notice provides more detail about the information that we use, the legal basis that we rely on in each case and your rights.

 

 

 

Complaints

If you have any complaints about the way we use your personal data please contact sss.gdpr@servoca.com who will try to resolve the issue. If we cannot resolve your complaint, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK).

 


 

 

Table: quick check of how we use your personal data

 

Purpose

Data used

Legal basis

Which rights apply?*

Recruitment decisions

Personal contact details, national insurance number, recruitment information, employment records, referencing, SIA and DBS .

Legitimate interest. It is in our interests to ensure we recruit the best possible workers in order to achieve our business goals and objectives. Necessary for the performance of the contract with you.

The generally applicable rights plus the right to object.

 

Right to work checks

Information relating to your right to work status, national insurance number, passport number, nationality, tax status information, and personal contact details.

 

Legitimate interest. It is in our interests to ensure that those who work for us have the right to work in the UK as well as to establish the statutory excuse to avoid liability for the civil penalty for employing someone without the right to undertake the work for which they are employed. Necessary for the performance of the contract with you

 

The generally applicable rights plus the right to object.

 

 

 

 

Administration of your contract including payment of wages/fee and expenses

Compensation history, national insurance number, personal contact information, bank account details, pension auto enrolment, statutory sick pay, payroll records and tax status information, start and end date of employment/engagement and date of birth.

 

Contractual necessity.

The generally applicable rights plus the right to data portability.

 

 

 

 

Compliance with our statutory duties to ensure a safe place of work and to ensure that you are fit for work

Information about your health, including any medical condition, health and sickness records and location of assignments.

Legal obligation.

The generally applicable rights only.

 

 

 

 

To monitor compliance with our policies

Personal contact details, CCTV footage and other information obtained through electronic means such as swipecard records.

 

Legitimate interest. It is in our interests to ensure workers/contractors are complying with our policies and client policies as non-compliance with policies can result in termination of engagement, ultimately affecting our day to day operations and business plans.

 

The generally applicable rights plus the right to object.

Fraud and crime prevention

Information about criminal convictions and offences committed by you, personal contact details and CCTV footage and other information obtained through electronic means such as swipecard records.

 

Public interest and legitimate interest. It is in our interests as well as our client ands in the interests of our workers/contractors to ensure the prevention of fraud and crime is monitored. This will ensure a safe workplace and client sites for all.

 

The generally applicable rights plus the right to object.

Audits

Recruitment information, engagement records, referencing, application form, DBS, right to work data, SIA licence and training records.

 

Legitimate interests. It is in our legitimate interest to ensure we pass the audits as required by our clients, the SIA and the British Standards to ensure we remain a respected provider of security services. Necessary for the performance of the contract with you.

The generally applicable rights plus the right to object.

Diversity monitoring

Gender and information about your race or ethnicity.

 

Public interest.

The generally applicable rights plus the right to object.

 

 

 

 

To deal with legal disputes

Personal contact details, engagement records, compensation history, performance information, photographs, CCTV footage and other information obtained through electronic means and information about criminal convictions and offences committed by you.

 

Legitimate interest. It is in our interests to process personal data to make and defend legal claims to ensure that our legal rights are protected.

The generally applicable rights  plus the right to object.

Business management and business planning

Information about your use of our information and communication systems, engagement records, location of assignments, training records,, wages and personal contact details.

 

Legitimate interests.  It is in our interests to undertake this processing to ensure we can improve any business operations which will ultimately improve the overall quality of the service we provide and work/the workplace. Workers/contractors will ultimately benefit as the workplace and its procedures may be strengthened.

 

The generally applicable rights plus the right to object.

Exit management at the end of your engagement

Personal contact details, payroll records, tax status information, end date of engagement, and engagement records.

Legal obligation and contractual necessity. Legitimate interest.

 

The generally applicable rights plus the right to object.

*The following generally applicable rights always apply: right to be informed, right of access, right to rectification, right to erasure, right to restriction and rights in relation to automated decision making. For more detail about your rights and how to exercise them please see Your rights in relation to your information