Privacy Notice Employees, Contractors and Candidates

What is the purpose of this document?

Bell is a data “controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to candidates, current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will advise you via our website, our intranet (bNet), or by other means of contact such as email.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using that information and what your rights are.

Data protection principles

The kind of information we hold about you

We may collect, store and use the following categories of personal information about you:

• Personal contact details such as name, title, addresses, telephone numbers and personal email addresses.
• Date of birth.

• Marital status and dependants.
• Next of kin and emergency contact information.
• National Insurance number.
• Bank account details, payroll records and tax status information.
• Salary, annual leave, pension and benefits information.
• Start date and, if different, the date of your continuous employment.
• Leaving date and your reason for leaving.
• Location of employment or workplace.
• Copy of driving licence.
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
• Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).
• Compensation history.
• Performance information.
• Disciplinary and grievance information.
• CCTV footage and other information obtained through electronic means such as swipe card records.
• Information about your use of our information and communications systems.
• Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied.

We may also collect, store and use the following more sensitive types of personal information:

• Information about your race or ethnicity, religious beliefs, sexual orientation, and political opinions.
• Trade union membership.
• Information about your health, including any medical condition and sickness records, including:
• where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill health, injury or disability, the records relating to that decision;
• details of any absences (other than holidays) from work including, but not limited to, time on statutory parental leave and sick leave;
• any health information in relation to a claim made under the permanent health insurance scheme; and
• where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.
• Genetic information and biometric data.
• Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about candidates, employees, workers and contractors throughout the application and recruitment process, either directly from the data subject or sometimes from an employment agency or background check provider. We may sometimes collect additional information from other third parties including, but not limited to, customers, social media platforms, on-line recruitment platforms, former employers, credit reference agencies or other background check agencies.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

How we will use information about you

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you or our customer and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

• Making a decision about your recruitment or appointment including in background and screening checks to validate information.
• Storing your details for the purposes of matching you with future vacancies we or our customers may have.
• Determining the terms on which you work for us.
• Determining whether your engagement is deemed employment for the purposes of Chapter 10 of Part 2 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) and providing you with a status determination statement in accordance with the applicable provisions of ITEPA 2003 or to comply with other local legislation relating to income tax and social security.
• Checking you are legally entitled to work in the jurisdiction that you will be working in.
• Paying you and, if you are an employee or deemed employee for tax purposes, deducting tax and National Insurance contributions (NICs) or making other legally required deductions.
• Providing company benefits to you.
• Inviting you to participate in any share plans operated by us or any group company.
• Granting awards under any share plans operated by us or any group company.
• Administering your participation in any share plans operated by us or any group company, including communicating with you about your participation and collecting any tax and NICs or other levies due on any share awards.
• Enrolling you in a pension arrangement.
• Liaising with the trustees or managers of a pension arrangement operated by us or any group company, your pension provider and any other provider of employee benefits.
• Administering the contract we have entered into with you or a customer, including to share some information such as your name, experience, skills, and business contact information with customers.
• Business management and planning, including accounting and auditing.
• Conducting performance reviews, managing performance and determining performance requirements.
• Making decisions about salary reviews and compensation.
• Assessing qualifications for a particular job or task, including decisions about promotions.
• Security vetting where this is required for the position.
• Gathering evidence for possible grievance or disciplinary hearings.
• Making decisions about your continued employment or engagement.
• Making arrangements for the termination of our working relationship.
• Education, training and development requirements.
• Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
• Ascertaining your fitness to work.
• Managing sickness absence.
• Complying with health and safety obligations.
• To prevent fraud.
• To monitor your use of our information and communication systems to ensure compliance with our IT policies.
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
• To conduct data analytics studies to review and better understand employee retention and attrition rates.
• Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

Situations in which we will use your sensitive personal information

In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below.

• We will use information about your physical or mental health, or disability status, to:
• ensure your health and safety in the workplace;
• assess your fitness to work;
• provide appropriate workplace adjustments;
• monitor and manage sickness absence; and
• administer benefits including statutory maternity pay, statutory sick pay, pensions and permanent health insurance.

We need to process this information to exercise rights and perform obligations in connection with your employment.

• If you leave employment and under any share plan operated by us or any group company the reason for leaving is determined to be ill health, injury or disability, we will use information about your physical or mental health, or disability status, in reaching a decision about your entitlements under the share plan.
• If you apply for an ill-health pension under a pension arrangement operated by us or any group company, we will use information about your physical or mental health in reaching a decision about your entitlement.
• If we reasonably believe that you or another person are at risk of harm and the processing is necessary to protect you or them from physical, mental or emotional harm or to protect physical, mental or emotional well-being.
• 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.
• We will use personal data and details of convictions for security vetting.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy, to carry out our legal obligations or to exercise specific rights in the field of employment law. In limited circumstances we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for such consent from us.

We do not need your consent where the purpose of the processing is to protect you or another person from harm or to protect your well-being and if we reasonably believe that you need care and support, are at risk of harm and are unable to protect yourself.

Information about criminal convictions

We envisage that we will hold information about criminal convictions for certain positions.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences for security vetting. We may share the outcomes of any security vetting with our customer where our contract with the customer and the services that you are providing for the customer require us to do so.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means. However, we will notify you in writing if this position changes.

Data sharing

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

Third parties includes customers, third-party service providers (including contractors and designated agents) and other entities within our group. Activities that are carried out by third-party service providers include but are not limited to: payroll, pension administration, benefits provision and administration, and IT services.

How secure is my information with third-party service providers and other entities in the group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. We never allow your data to be sold.

When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group: as part of our regular reporting activities on company performance; in the context of a business reorganisation or group restructuring exercise; for system maintenance, support and hosting of data. We will share personal data relating to your participation in any share plans and pension arrangements operated by us or any group company with other entities in the group for the purposes of administering the share plans and pension schemes.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to relevant tax authorities, disclosures to stock exchange regulators, and disclosures to shareholders such as directors’ remuneration reporting requirements.

Transferring your personal data internationally

Under data protection law, we can only transfer your personal data from the UK or the EEA to a country or international organisation outside the UK or the EEA where:

• the UK government or, where the EU GDPR applies, the European Commission, has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an “adequacy decision”);
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law.

These are explained below.

Adequacy decision

If you are in the UK or the EEA, we may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

• all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
• Gibraltar;
• The Republic of Korea; and
• Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

An adequacy decision can also be used for transfers between the UK and the EEA.

In addition, in accordance with an adequacy decision we may transfer personal data to companies in the United States that participate in the Data Privacy Framework or the UK extension of it (known as the Data Bridge).

Other countries or international organisations we may transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally approved standard data protection contract clauses.

Transfers under an exception

We may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g.:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish, exercise or defend legal claims.

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Additionally, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. Details of retention periods for different aspects of your personal information are available in our Data Retention Policy which is available upon request.

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 the personal data.
• The purposes for which we process the personal data and whether we can achieve those purposes through other means.
• The applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use that information without further notice to you. Once you are no longer an employee, worker or contractor of Bell, we will retain and securely destroy your personal information in accordance with our Data Retention and Destruction Policy or applicable laws and regulations. We retain personal data relating to unsuccessful candidates for six (6) months following the conclusion of the recruitment process, unless a longer retention period is agreed with the individual. For successful candidates, we retain recruitment, screening, and employment-related data for the duration of employment and for seven (7) years after employment ends, unless a longer retention period is required by law.

Rights of access, correction, erasure and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Withdraw consent where you have provided your consent to the collection, processing, or transfer of your personal data. You may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us using the mechanism below.
• Request access to your personal information (commonly known as a data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us using the contact details below.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us by emailing PeopleTeam@bell-integration.com. . Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

How to contact us

If you have any questions about this privacy notice, please contact us by emailing PeopleTeam@bell-integration.com.

Making a Data Protection Complaint to Us

If you want to make a data protection complaint, please contact us in the first instance at PeopleTeam@bell-integration.com so that we may address any concerns you might have in line with our complaints process. We will contact you about your data protection complaint within 30 days of receipt.

If you are dissatisfied with the outcome of your complaint, you may exercise your right to contact the Information Commissioner (IC) at:

Information Commissioner

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Website: https://ico.org.uk/global/contact-us/

Telephone: 0303 123 1113