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Employee Privacy Notice

At CLEAR we take the protection of our employee’s data seriously. This Privacy Notice explains how we use the information we collect about you and who we share it with as well as your rights and how to exercise them. 

This Privacy Notice applies to current, former and prospective employees of all Group companies, including acquired businesses.

Collection and processing of personal data

As your employer, we collect and process information about you for a variety of reasons. 

We need contact details (name, address, telephone numbers, email addresses) and bank details so that we can meet our employer and statutory obligations to you.

We collect tax, national Insurance, date of birth and right to work information in order to pay your salary and benefits and meet legal obligations. We may also require information about your dependants where they are included in your benefits.

We may hold health information so that we can ensure a safe working environment for our staff. This may also be required for employee benefits provisions.

We require details of your employment history, training and qualifications in order to assess applications from internal and external candidates.

We collect details of financial history, criminal or civil action and regulatory history in order to assess fitness and propriety to perform FCA regulated activities.

Where you drive on company business, we will request copies of driving licence, insurance and of vehicles as evidence that you are permitted to do so.

Data protection legislation explains that we are only allowed to collect or use your personal information if the reason to do so meets certain conditions. The exact reason will vary depending on the specific circumstances. The legal bases that we rely on are:

  • For the performance of a contract: Your employment contract means that we must continue to use the personal information we hold. As well as the information you provide, it will include details of training, performance appraisals, references or employment disputes (disciplinary or grievance)
  • To meet a legal obligation: As an employer, we are required to meet a variety of legal, regulatory and statutory obligations. These include HMRC and pension requirements, health and safety prevention of crime and Financial Conduct Authority rules.
  • Legitimate interests: The law allows us to hold or use personal information if we have a legitimate reason to do so. For example, we will keep records of your employment, including former employees, in case any potential employment dispute arises in the future so that we can establish the circumstances and, if appropriate, defend our position. We may also keep information relating to your health which including reasons for absence to comply with health and safety or occupational health obligations and to assess whether we need to make any reasonable adjustments and/or administer sick pay. Where we rely on this basis, we will balance our interests with your own rights under data protection laws. For example, we will maintain a policy so that we do not keep information longer that is reasonable.
  • Consent: If no other legal basis applies, we may rely on your consent to use your personal data, for example, we would ask for your consent to seek a medical report from your GP if adjustments to working arrangements are required for medical reasons.
 Other Personal information you may provide

Where you provide information about other individuals, such as family members, you are responsible for ensuring they are aware of the reasons and or their rights. You can do so by drawing their attention to this notice.

What other information might we collect about you?

We may obtain personal information from other sources in relation to your employment. Examples include previous employers or from customers or trading partners in relation to your employment.

For some employees, we may conduct credit or criminal records checks with approved agencies. We require all such parties to comply with data protection legislation.

Who do we share your information with?

In the course of your employment, there are a number of situations where your personal information will be shared with other parties. These include:

  • To pay your salary and benefits
  • Where we use external systems or databases to collect and maintain information about employees (training, holidays and absence, staff declarations)
  • To arrange training with external providers
  • Where your role requires information to be shared with product providers or suppliers
  • Where we are required or permitted to do so by law or regulation, such as prevention of financial crime
  • With third party service parties unrelated to insurance, such as data hosting / storage providers or technology suppliers
  • If we undergo a reorganisation, or if some or all of our business or assets change ownership, we may transfer your personal information to the successor company to ensure continuity of service.

Our agreements with third parties include requirements to comply with relevant data protection legislation so that your rights are maintained.

With the exception of our payroll provider, we will not send your personal information outside of the European Economic Area (EEA). The provider will host personal data in the USA and processing takes place in the UK, India and Romania. Data transfer outside the EU will be in accordance with EU approved model contract clauses and / or Binding Corporate Rules (BCRs) approved by all relevant EU Data Protection Authorities.

Retaining your data

There are a number of reasons why we will retain personal information, such as legal or statutory obligations, to provide references or in case of disputes.

For most information, we will retain records for up to seven years after you have left the company.

Where we have obtained your consent to hold personal information, we will retain it for as long as we have your consent, subject to the above timescales.

Staying in control of your data

Data regulations and legislation provide you with certain rights over the personal information we hold.

  • You can request details of some or all of the personal information we hold about you. This is often referred to as a Subject Access request.
  • Where you believe personal information is no longer required you can request that it is deleted. However, we may not be able to do so it we still have a legitimate basis for keeping it.
  • If you believe that personal information we hold about you is incorrect you can ask us to correct it.
  • You can request a copy of personal information to be provided in a portable (electronic) format. We will endeavour to meet such requirements where the format is reasonable and in common use.
  • Where you have provided consent, you can withdraw your consent at any time.

In addition to these, you can ask us to restrict the use of your personal data if any of the above apply, but you do not wish us to delete it.

We aim to meet any requests promptly and as fully as possible. We may contact you to further understand your requirements in order to expedite your request.  In some cases, we may be prevented from completing requests for legal reasons or due to conflicting legitimate interests. If this is the case, we will explain our reasons why.

There is no charge for requests for copies, amendments or deletions of personal information. However, we reserve the right to charge where requests are unreasonably frequent or excessive.

Getting help

If you have any questions regarding this Privacy Notice or wish to make a request regarding your personal information, please contact:

The Data Protection Manager

The Clear Group

1 Great Tower Street

London

EC3R 5AA

If you wish to make a complaint

If you are dissatisfied about the way we have handled your personal information and wish to complain, you should contact the Data Protection Manager using the details above. We will aim to investigate and respond promptly and will provide a written response.

If you remain dissatisfied, or believe that we are not handling personal information in compliance with appropriate laws and regulations, you are entitled to raise your complaint with the Information Commissioner’s Office who can be contacted at:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF