Privacy Policy

Bradford Children and Families Trust Employee Privacy Notice

This privacy notice tells you what to expect us to do with your personal information when you apply to work for us, or when you are employed by us.

Contact details

To contact our Data Processing Officer, email dpo@bradfordcft.org.uk

1. What information we collect and use, and why

Staff recruitment, administration and management

We collect or use the following personal information as part of staff recruitment, employee administration and management:

• Contact details (e.g. name, address, telephone number and personal email address)
• Date of birth
• National Insurance number
• Gender
• Photographs (e.g. staff ID card)
• Copies of passports or other photo ID
• Copies of proof of address documents (e.g. bank statements or bills)
• Marital status
• Next of kin or emergency contact details
• Employment history (e.g. job application, employment references or secondary employment)
• Education history (e.g. qualifications)
• Right to work information
• Details of any criminal convictions (e.g. DBS checks)
• Performance records (e.g. reviews, disciplinary records, complaints or disciplinary action)
• Training history and development needs
• Monitoring employees’ IT use
• CCTV footage or other recordings

We also collect or use the following special category information for staff recruitment, administration and management. This information is subject to additional protection due to its sensitive nature:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Trade union membership
• Sexual orientation information
• Disability information

Salaries and pensions

We collect or use the following personal information as part of managing salaries and pensions:

• Job role and employment contract (e.g. start and leave dates, salary, changes to employment contract or working patterns)
• Time spent working (e.g. timesheets, authorised leave forms)
• Expenses, overtime or other payments claimed
• Leave (e.g. sick leave, holidays or special leave)
• Maternity, paternity, shared parental and adoption leave and pay
• Pension details
• Bank account details
• Payroll records
• Tax status
• Trade Union membership

We also collect or use the following special category information for managing salaries and pensions. This information is subject to additional protection due to its sensitive nature:

• Trade union membership
• Health information

Staff health and wellbeing

We collect or use the following personal information for managing staff health and wellbeing:

• General health and wellbeing information
• Occupational health referrals and reports
• Fit notes (e.g. Statement of Fitness for Work from a GP or hospital)
• Return to work forms
• Accident at work records
• Access needs or reasonable adjustments
• Protected Characteristics (as defined by the Equality Act and s.75 of the Northern Ireland Act for the purpose of equal opportunities monitoring)

We also collect or use the following special category information for managing staff health and wellbeing. This information is subject to additional protection due to its sensitive nature:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Health information, including disability

2. Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

3. Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information as part of staff recruitment, administration and management are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information as part of managing salaries and pensions are:

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information as part of managing staff health and wellbeing are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

4. Where we get personal information from

We collect your information from the following places:

• Directly from you
• Employment agency
• Schools, colleges, universities or other education organisations
• Referees (external or internal)
• Occupational Health and other health providers
• Pension administrators or government departments (e.g. HMRC and DWP)
• Trade Unions
• Staff benefit providers
• Public sources (e.g. LinkedIn or other websites)
• CCTV footage or other recordings
• DBS (Disclosure and Barring Service)
• SWE (Social Work England)

5. How long we keep information

We keep your information in line with our retention schedule (Appendix 1). For further information on how long we store your personal information, or the criteria we use to determine this, please contact us using the details provided above.

6. Who we share information with

In some circumstances, we may share information with the following organisations:

• Training suppliers
• HMRC
• Employee benefit schemes
• Health and benefit suppliers
• External auditors
• Professional consultants, including legal teams
• Referees (in and out)

7. Data processors

We use the following data processors for the following reasons:

• CBMDC payroll - This data processor processes payroll information on the trust’s behalf
• Tribepad - This data processor stores data on our behalf
• Civica - This data processor stores employee data on our behalf
• West Yorkshire Pension Fund - This data processor administers pensions on the Trust’s behalf
• Spectrum Life - This data processor provides counselling services on the Trust’s behalf
• UKIM - This data processor provides Occupational Health services on the Trust’s behalf
• Disclosure and Barring Service - This data processor conducts criminal records checks, including checks of the barred list where applicable to the role
• Veritau - This data processor provides DPO services to the Trust’s Information and Governance team

8. Raising a complaint

If you have any concerns about our use of your personal data, please send your complaint to us at dpo@bradfordcft.org.uk. It is important that you take this first step so we can resolve any complaints internally in the first instance. By raising a complaint internally, we are able to work with you to understand the complaint, and work with you to resolve it.

If after raising a complaint with us, you remain unhappy with how we’ve used your data, you can raise a complaint with the ICO. The ICO’s address is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint

Appendix 1 – Retention Schedule for People and Talent Team and for Payroll Activity

Service Function	Description of Records	Retention Period
HR Timesheets	Copies of staff timesheets for overtime or casual hours (pay records relating to these held by Payroll separately)	3 years
HR Signing in books – including records of offsite visits, visitor logbooks and contractors signing in records	Staff Attendance books, visitor books and contractors’ attendance records	3 years except for records for residential facilities for children and young people, which should be retained for 15 years
HR Flexisheets	Flexitime staff records	3 years
HR Car allowance records / expenses records	Employee mileage and expenses forms retained locally by staff (Payroll keep their own records of these once processed)	3 years
HR Return to work forms / absence records	Forms recording return to work interviews	3 years
HR Sick notes	Staff fit notes issued by doctors	3 years
HR Sickness absence - informal	Hard copy supporting docs (e.g. return to work discussions, absence monitoring records etc.)	3 years
HR Sickness absence - formal	SAP record (if goes to capability hearing)	6 years after the year in which the employee has ceased employment
HR Reasonable adjustments	Record of any adjustments in place to enable person to return to work	6 years after the year in which the employee has ceased employment
HR Informal disciplinary, grievance, capability	Documented records of any informal action taken	3 years
HR Formal disciplinary, formal capability or sickness absence – hard copy supporting documents (originals of hearings, outcome etc. retained by HR - do not keep copies locally)	Documented local records (incl. case file) of any formal investigations and outcomes	6 months
HR Formal grievance – hard copy supporting documents (originals of grievance and outcome retained by HR - do not keep copies locally)	Local records / copies of staff formal grievances where the original is kept by HR on the employee personnel file	6 years after the year in which the employee has ceased employment
HR Whistleblowing – hard copy supporting documents (including allegations, reports and recommendations retained by HR – do not keep copies locally)	LGO complaints: 3 years. Corporate and professional complaints: 6 years; statutory complaints - as per CSC retention policy (up to 100 years if child is in care)	Review 3 years after date of investigation hearing / investigation report; destroy or retain as per complaint requirement
HR Career grade progression employee information	Notice of honorariums, regrades, new spinal point or grade - retained with the central employee personnel record	6 years after the year in which the employee has ceased employment
HR Individual staff members structure information	Assimilation, redeployment, redundancy, leaving notice, retirement, ill health, dismissal, death	6 years after the year in which the employee has ceased employment
HR Organisational Structure	Staff structure charts. New data overwrites existing.	Archived records to be kept for 5 years
HR Restructure information	Team and service staffing restructures	5 years from creation
HR Workforce development Training records	Individual staff training records held locally by managers	If these are not kept centrally by HR, then 6 years after the year in which the employee has ceased employment
HR Redeployment register	Details of staff registered for redeployment	6 years
HR TUPE records	Staff transferred out to external providers	6 years
HR Absence records	Any absence related record e.g. annual leave sheets, special leave	3 years
HR Job Evaluation records	Post grading records	Duration of the post
HR Grading information	Related to post grading	7 years
HR Staff benefits	Details of staff in receipt of metro cards, rail cards, NCP partnership initiative	7 years
EHWB Employee health & well-being records	Occupational Health and EHWB records for staff including medical details	3 years after employee leaves organisation, unless COSHH or legislative mandatory health surveillance, which must be kept for 40 years
HR Recruitment records - non successful applicant	Details of non-successful candidates within a specific recruitment process	6 months
Recruitment record - successful applicant	Contract form and recruitment records in relation to a successful candidate (including references, qualifications)	Transfer to HR file and retain for 6 years after the year the employee has ceased employment
Job Profiles	Individual job profile for staff member	7 years after leaving
HR Vacancy adverts	Adverts published including vacancy approval form	12 months
Personnel file	The full employee personnel file retained centrally by HR (on Civica) or local records held by Managers	7 years after the employee has ceased employment
Workforce development records	Staff training taken through workforce development central services	7 years after the employee has ceased employment
Apprenticeship records	Any information relating to individuals undertaking an apprenticeship	7 years after the employee has ceased employment
DBS Employment checks	Employee checks undertaken where the post requires this. DBS certificate not to be kept – disclosures to be logged	ID documents to be retained for 2 years
Industrial Relations	OJC meeting minutes, collective agreements, consultation documents	12 years or as long as agreement in place
All other HR documents (letters of appointment, contract extensions, changes of hours, referrals to EHWB, OJC minutes or anything else not on the above list)	Duplicate copies sent to managers for information	Do not retain after current usefulness has ended, as original is held by HR
Manager's information	Manager's dashboards. New data extracted from SAP is uploaded monthly which overwrites existing data.	Old data is archived for 5 years
Primary Payroll Records Pay, Tax and NIC	Employee or Member Payroll Record; Timesheets uploaded to payroll record (Inc Overtime); Annual Leave / Sickness / Special Leave Records; Sick notes; Bonus / Contractual Payments & Supporting Documents; Other related Records & Correspondence; Payslips	Current Year + 6 Tax Years
Payroll Expenses	Car Allowance; Subsistence; Mileage; Travel Expenses; VAT Receipts	Current Year + 6 Tax Years
Payroll Deductions	Credit Union; Health Plans; Union Membership; Other Non-Statutory Deductions	Current Year + 6 Tax Years
Pensions – Member Employee Records	‘Opt-in’ Notice / Automatic Enrolment Date / Active Membership Commencement Date; Employee or Member Payroll Record (including Name, Address, DOB, Gender, NI Number, current Bank Details etc.); Gross Qualifying Earnings in each relevant pay reference period; Actual Contributions each relevant pay reference period; ‘Opt Out’ Notice; Date of Contributions Paid Over	Indefinitely
Other payroll records not required to be submitted to HMRC	Various	Current Year + 3 Tax Years