Privacy Policies

INTRODUCTION

rove is committed to protecting your privacy. We are the controller of the personal data processed for the purposes set out below and we are responsible for looking after it.

This policy relates to our use of the personal data of our employees and other members of our staff and personnel (such as contractors and other workers). It explains how we use, store and share the information we collect about you, how you can exercise your rights in respect of that information and the procedures that we have in place to safeguard your privacy.

 

CONTACTING US

rove Limited is registered with the Information Commissioners Office (ICO): registration number: Z3320152

We have appointed a data protection officer who can be contacted at info@roveconsultancy.co.uk if you have any questions, comments or concerns about this policy or how we handle your personal data, or if such information changes at any time.

 

THE PERSONAL DATA WILL WE COLLECT ABOUT YOU

Personal data means any information that relates to an identified or identifiable individual. The types of personal data that we may collect, and process includes:

• Identification information (e.g. title, name, your job title or position, marital status, tax payer identification such as national insurance information, passport number etc), education and professional qualifications
• Contact information (e.g. your postal address, email address and phone number(s) for both work and home)
• Financial information (e.g. payment-related information including bank account information, payroll records, salary information)
• Residency and work permit status, including visa documentation
• Technical information (e.g. IP address, details of visits made to our online services such LMS logs)
• Special categories of personal information such as health information, sickness absence, access requirements or special needs or religious beliefs information, dietary preferences or allergies
• Images, still and moving photography taken when attending our events, photos and videos published to or streamed via the intranet and our social media channels
• Diversity information (e.g. sex, gender, ethnicity etc, in diversity questionnaires)
• Career performance related information
• Character suitability information (e.g. references, criminal offences information, criminal records checks)
• Any other information relating to you which you may provide to us.

 

WHERE WE COLLECT THIS INFORMATION FROM

We collect this information directly from you (e.g. when you provide your CV, attend catch-ups and interviews or contact the Management team).

We will also collect the personal data about you from:

• Providers of background checks and referees
• The public domain (e.g. LinkedIn or other social media)
• Notes and records kept throughout your work including absences, expenses claims, questionnaires, health and safety information including accident reports, performance reviews, and details of any grievances/ disciplinary action or complaints/whistleblowing reports
• Customers
• Our IT systems (including emails and chat systems such as Microsoft Teams)
• Third parties (who may be acting as a controller) including our insurers, government departments and regulators

 

HOW WE USE YOUR PERSONAL DATA

The following table sets out why we process your personal data and also our lawful basis for processing. We may rely on more than one lawful basis for processing your personal data depending on the context of the processing activity.

PURPOSE/ACTIVITY	PERSONAL INFORMATION USED	LAWFUL BASIS
Non-‘Special Categories’ of Personal Information
Making a decision about your recruitment or appointment and managing the recruitment process and determining the terms on which you work for us	All the personal information we collect for the purposes of the recruitment process	We need this information to be able to perform and administer the recruitment process for you to engage you. This is necessary to enter into a contract with you.
Checking you are legally entitled to work in the UK	Personal contact details and identification documents and right to work documentation	We have a legal obligation to do so.
Producing and maintaining business records, staff directories, websites, brochures and other internal and external business documentation and materials	Personal contact details and employment records	We have a legitimate interest to maintain up to date business records and materials.
Paying you and, if you are an employee, deducting tax and National Insurance contributions	Personal identifiers and transaction and payment information	To be able to manage and perform our contract with you.   We have a legal obligation to do so
Providing benefits of employment or working, including flexible benefits and liaising with benefit providers	Personal identifiers, salary, annual leave, pension and benefits entitlement, transaction and payment information	To be able to manage and perform our contract with you.   We may have a legal obligation to do so.
Administering the contract we have entered into with you	All your personal information excluding ‘special categories’ of personal information and criminal records information	To be able to manage and perform our contract with you.
Conducting performance reviews, grievance or disciplinary hearings, managing performance and determining performance requirements and making decisions about compensation and benefits	Performance, disciplinary and grievance information, employment records, compensation history, salary, annual leave, pension and benefits	We have a legitimate interest to ensure that our workers are meeting their performance objectives and that the business is managing and controlling the performance process effectively.   To be able to manage and perform our contract with you.
Business management and planning, including accounting and auditing, conducting our normal business operations and managing our relationship with you	All your personal information excluding ‘special categories’ of personal information and criminal records information	To be able to manage and perform our contract with you.   We have a legitimate interest to run and manage our business.

Assessing qualifications for a particular job or task, including decisions about promotions and ascertaining your fitness to work, education, training and development requirements	Personal identifiers, performance, disciplinary and grievance information, employment records, compensation history, salary, annual leave, pension and benefits and other personal information excluding ‘special categories’ of personal information and criminal records information	We may have a legal obligation to do so.   To be able to manage and perform our contract with you.   We have a legitimate interest to run and manage our business and to ensure that our workers are suitably trained.
Making decisions about your continued employment or engagement or termination of our working relationship	Personal identifiers, performance, disciplinary and grievance information, employment records, compensation history, salary, annual leave, pension and benefits	We have a legitimate interest to ensure that the workers we engage continue to be suitably qualified and/or appropriate for their role within the business.
Managing sickness absence	Personal identifiers, attendance history and performance	To be able to manage and perform our contract with you.   We have a legitimate interest to ensure that the workers we engage continue to be suitably qualified and/or appropriate for their role within the business.
Complying with health and safety obligations	Personal identifiers and other information obtained through electronic means, working environment information including any home-working assessment records	We have a legal obligation to comply with Health and Safety laws.   We also have a legal obligation to report any accidents at work in accordance with health and safety laws.
Dealing with legal disputes involving you, or other employees, workers, directors and consultants, including accidents at work	All your personal information excluding ‘special categories’ of personal information and criminal records information	To be able to manage and perform our contract with you.
For the purposes of ensuring the security of our systems and our information, to ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution	Personal identifiers and other information obtained through electronic means.   Use of our information and communications systems, including the computers and fixed and mobile phones that we allow you to use, passwords, personal identification numbers, IP addresses, usernames and other IT system identifying information	We have a legitimate interest in ensuring our systems are secure.   To be able to manage and perform our contract with you.
To facilitate the use of our IT systems and monitor your use of our information and communication systems	Personal identifiers and other information obtained through electronic means. Use of our information and communications systems, including the computers and fixed and mobile phones that we allow you to use, passwords, personal identification numbers, IP addresses, usernames and other IT system identifying information	We have a legitimate interest in ensuring that our workers use our computer systems and information correctly and efficiently and in compliance with our IT policies.   To be able to manage and perform our contract with you.
To comply with our legal obligations, for example in relation to PAYE, National Insurance, Companies House filings	Personal identifiers, transaction and payment information, national insurance number and other tax or governmental identifiers bank account details, payroll and tax status, name, address, date of birth, other directorships	We have a legal obligation to do so.
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution	Personal identifiers and other information obtained through electronic means. Use of our information and communications systems, including the computers and fixed and mobile phones that we allow you to use, passwords, personal identification numbers, IP addresses, usernames and other IT system identifying information	We have a legitimate interest in ensuring our systems are secure.
For the purposes of equal opportunities monitoring	Name, title, date of birth; gender; marital status; salary, annual leave, pension and benefits; location of employment or workplace	We may have a legal obligation to do so and we have a legitimate interest in doing so to make sure our business is a fair place to work

Storage of records relating to you and also records relating to our business	All non-‘special categories’ of personal information	To be able to manage and fulfil our contract with you, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records
For the purpose of complying with any regulatory requirements	All the personal information about you excluding special category information and criminal records data	We may have a legal obligation to comply with regulatory requirements and we have a legitimate interest in complying with regulatory requirements

 

‘Special Categories’ of Personal Information or Criminal Records
Storage of records relating to you and also records relating to our business.	All special categories of personal information	We process special category personal data on the basis of the ‘special category’ reasons for the for processing of your personal data referred to above.   For criminal records information we process it on the basis of legal obligations or based on your explicit consent.
We will use information relating to your absence from work, which may include sickness absence or family-related absences, to comply with employment and other laws.	Information about your health, including any medical condition, health and sickness records, medical records and health professional information	We process special category personal data on the basis of the ‘special category’ reasons for processing of your personal data referred to above.
We will use information about your physical or mental health to provide you with benefits under your contract	Information about your health, including any medical condition, health and sickness records, medical records and health professional information	We process special category personal data on the basis of the ‘special category’ reasons for processing of your personal data referred to above.
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	Information about your health, including any medical condition, health and sickness records, medical records and health professional information	We process special category personal data on the basis of the ‘special category’ reasons for processing of your personal data referred to above.
We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation or political beliefs, to ensure meaningful equal opportunity monitoring and reporting.	Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions	We process special category personal data on the basis of the ‘special category’ reasons for processing of your personal data referred to above.
We will use and retain information about criminal convictions to comply with law and in order to determine your eligibility to undertake particular types of work.	Information about your criminal convictions and offences	For criminal records information we process it on the basis of legal obligations or based on your explicit consent.

 

DATA SECURITY

We have in place appropriate policies, procedures and organisational measures to protect your personal data from unauthorised or unlawful processing, and against accidental loss, destruction or damage. We also have procedures in place to deal with any data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.

SHARING YOUR DATA

We will only disclose your personal data to:

• Third parties (who may be acting as controller) such as our insurers, legal and other professional advisors, regulators, administrators and government departments, credit reference agencies, and fraud prevention agencies
• Other third-party suppliers, business partners and sub-contractors for business administration, support, processing, services, or IT purposes
• Customers, potential customers or other organisations in our sector to facilitate our work, or the provision or promotion of our services
• HMRC or other tax bodies or agencies to comply with our legal and regulatory obligations

INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA

We may transfer your personal data to countries outside the United Kingdom in order to provide our services. The laws in these countries may not offer the same level of protection for personal data as in the United Kingdom.

If we transfer personal data to countries outside of the United Kingdom, we will do so in a lawful way and may rely on a lawful exception to the rules relating to overseas data transfers (for example, the transfer is necessary to perform a contract with you, which is in your interests)

DATA RETENTION

We will only hold information about you 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.

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

In some circumstances you can ask us to delete your personal data. Please see below for more information about your right to erasure.

 

YOUR RESPONSIBILITIES

You are responsible for helping rove keep your personal data up to date. You should let the Management team know if the information you have provided to us changes, e.g. if you move house or change the bank account into which your salary is paid.

 

YOUR DATA PROTECTION RIGHTS

Under data protection law, you have rights in relation to your personal data:

• To be informed – A right to be informed about the personal data we hold about you.
• Of access – you have the right to access the personal data we hold about you
• To rectification – you have the right to ask us to correct any information you think is inaccurate or incomplete.
• To erasure – a right to ask us to delete the personal data we hold about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for, where you withdraw your consent if we are using your personal data based on your consent, where you object to the way we process your data (see the right to object described below)
• To restrict processing – in certain circumstances, a right to restrict our processing of the personal data we hold about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us, where you would have the right to ask us to delete the personal data but would prefer that our processing is restricted instead, where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for the purposes of establishing, exercising or defending legal claim
• To object – you have the right to object to the processing of your personal information where our lawful basis is for the purpose of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process the personal data which override your rights or which are for the establishment, exercise or defence of legal claims.
• To data portability – you have the right to ask that we transfer the personal information you gave to us to another organisation, or to you, in certain circumstances.
• To withdraw – a right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with newsletters).
• To complain – you have the right to make a complaint to our supervisory authority, the Information Commissioner’s Office (ICO)

We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your personal data.

 

Changes to this Privacy Notice

This notice will be reviewed every year to ensure that it is effective and complies with current good practice. A review will be carried out sooner should there be any changes to statutory requirements.

We reserve the right to update this privacy notice at any time.