How we collect personal information about you and how it is used
During the course of your employment contract we will need to collect, store and process personal data you have given us, relating to your employment. This will include, but is not limited to,
- Address and contact details
- Equality & Diversity information; gender, ethnicity, religion, marital status, sexual orientation, disability (known as ‘Special Categories’)
- Health information
- Next of kin and family details*
- Bank and financial details
- Driving licence, vehicle details
- Any criminal or driving convictions (for certain roles)
- Declarations of interest
*to be used in the case of an emergency. When you provide this information, we assume that you do so with their full knowledge and consent.
Data will be used for, but is not limited to,
- Paying and reviewing salary and other remuneration benefits
- Paying your pension
- Conducting appraisals, 1:1 reviews and other management interventions
- Providing appropriate health, medical and welfare support to support you in performing your role
- Providing Health assessments for night workers (if applicable)
- Lone Worker Risk Assessments
- Providing reasonable adjustments in the workplace including Personal Evacuation Plans if you have a disability or physical impairment
- Providing or arranging training and qualifications relevant to your role
- Identifying you as an Aster employee, ID badges etc.
- Company vehicle tracking
- Providing references and information to future employers or other third parties such as landlords
- Providing information to governmental and statutory bodies such as the HMRC, Department of Work and Pensions, Health & Safety Executive, Child Support Agency, Courts Service
- Providing information to third parties in the event of closure, merger, transfer or takeover of all, or part of, Aster Group.
Processing Special Categories of Personal Data
In the course of your employment with Aster, we may need to process Special Categories of your personal information where you have provided these to us.
Special Categories of data include;
- Racial or ethnic origin
- Political opinions
- Religious beliefs, or other beliefs of a similar nature
- Trade union membership.
- Physical or mental health or condition
- Sexual life
- Commission or alleged commission of any offence
- Any proceedings for any offence committed, or alleged to have been committed.
Under Data Protection law, Special Categories of personal information can only be processed where there is a specific lawful basis for doing so.
As an employer, our primary lawful basis under the Data Protection Act 2018 is ‘where the processing is necessary for the purposes of performing or exercising obligations or rights of the controller or the data subject under employment law’. This includes processing activities such as administering your work pension, providing reasonable adjustments in the workplace in terms of disability or health needs and administering maternity, paternity and sickness benefits relating to your employment.
In line with our Equality and Diversity Policy Aster endeavour to provide employment and a working environment equally accessible to all staff without discrimination or prejudice. To allow us to monitor this, employee equality and diversity (‘Special Category’) data will be on your employee records but will also be used for monitoring and statistical purposes where it will be aggregated and anonymised.
Outside of these purposes, our primary lawful basis is ‘individual consent’, where you have opted for an additional employee benefit or programme such as healthcare benefits. In these cases we will gain your consent to process your Special Categories of information.
Providing your equality and diversity data is voluntary. You may amend or delete this data at any time during your employment through your employee self-service portal or by contacting People Services.
Who we share your data with
We are required by law to provide data relating to your employment to statutory agencies such as HMRC, Department of Work and Pensions, Health & Safety Executive, Child Support Agency, Courts Service.
In the course of your employment we may also share your data with third party agencies acting on our behalf (our ‘Data Processors’). Any such parties are only permitted to act on our instructions and in accordance with Data Protection legislation.
We may also share your data with third parties such as prospective employers or letting agencies for reference purposes if requested. In these cases we will seek your consent prior to sharing.
Sharing ‘Special Categories’ of information
If applicable to your role, information will be shared with an Independent Safeguarding registered body regarding suitability for working with children and vulnerable adults.
To comply with our Transport Operators Licence, we will need to share any driving convictions employees in certain roles may have.
We may need to share medical information with contracted third party medical advisory bodies if applicable to your role or health needs, e.g. if you are a night worker or are on a recuperative work plan due to ill health.
We offer various colleague welfare support options for staff, including colleague support networks and third party counselling however we do not share your data, instead you share data directly. In these cases, we ensure that any information you give is treated in the strictest of confidence, in accordance with Data Protection guidelines and not shared or used for any other purposes.
Aster employees have the option to opt into a number of benefits schemes provided by third parties. As your employer we will signpost you to these third parties only. In these cases, the providers are the ‘Data Controller’ regarding your data, not Aster. Any personal data you have provided to these parties will not be shared back to Aster other than where it has been aggregated and anonymised for statistical and monitoring purposes or for payroll purposes.
We may on occasion ask you for your feedback on working for Aster. This information will be used to improve the employee experience of working for Aster. This data will always be anonymised and will not be held on your employee records.
Promotional photographs and articles
During your employment at Aster, our Communications and Media teams may obtain promotional photographs or articles relating to your role or team. These may be published in articles on the Aster website, social media platforms and other web or hard copy communications.
We’ll cease to hold or use photos of which you are a key figure within 2 months of you leaving, however should you be captured in a group photo, these may continue to be used for up to 6 years then destroyed, but informal images may continue to exist. Photographs in print publications previously circulated may continue to exist past this time.
All communications you may send or receive though Aster communication channels and devices (e.g. email, phone, instant messages, Aster social media pages, post, fax), including any personal communications by you using these channels, are treated as the property of Aster Group (and not private) communication and as such, may be monitored, intercepted and read by Aster Group for the purpose of ensuring compliance with its procedures and also for business purposes.
How long information is kept for
The information you provided both during your application process and the course of your employment will be stored in your Aster employee file for the duration of your employment. If you leave your position with Aster it will then be retained for 6 years after which time it will be securely destroyed, unless there is a legal reason for retaining it e.g. your pension.