In line with the General Data Protection Regulation (GDPR) JTL have a legal obligation to inform all employees of how and why the organisation collects and processes personal data relating to its employees to manage the employment relationship. JTL is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

This notice applies to current and former employees and workers.

What information does JTL collect?

JTL collects and processes a range of information about you. This includes Personal Details (your name, address and contact details, including email address and telephone number, date of birth, gender, driving licence information and your photograph.

  • the terms and conditions of your employment;
  • CCTV footage and building entry records;
  • details of your qualifications, skills, experience and employment history, includingstart and end dates, with previous employers and with the organisation;
  • information about your remuneration, including entitlement to benefits such aspensions, insurance or private medical cover;
  • details of your bank account, tax codes and national insurance number;
  • information about your marital status, and emergency contacts;
  • information about your nationality and entitlement to work in the UK;
  • details of your schedule (days of work and working hours) and attendance at work;
  • details of periods of leave taken by you, including holiday, sickness absence, family
    leave, and the reasons for the leave;
  • details of any disciplinary or grievance procedures in which you have been involved,including any warnings issued to you and related correspondence;
  • assessments of your performance, including appraisals, performance reviews andratings, training you have participated in, performance improvement plans andrelated correspondence;
  • information about medical or health conditions, including if you have a disability forwhich JTL needs to make reasonable adjustments;
  • equal opportunities monitoring information, including information about your ethnicorigin, or disability.

JTL collects this information in a variety of ways. For example, data is collected through application forms, obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of, or during, employment and from correspondence with you; or through interviews, meetings or other assessments. JTL will also obtain a photo for your personnel record and identity pass on our HR System.

In some cases, JTL collects personal data about you from third parties, such as references supplied by former employers, information from criminal records checks permitted by law (DBS Disclosure). Third party information would only be obtained with your explicit prior consent.

Data is stored in a range of places including your personnel file and HR and IT systems; your personal information can only be accessed by specific personnel via specific systems.

Sensitive data e.g. bank details; would be in an area with higher security and very limited access to protect your rights.

Why does JTL process personal data?

JTL needs to process data to enter into an employment contract with you and to meet its obligations under that contract. For example, JTL needs to process your data to provide you with an employment contract, to pay you in accordance with your contract and to administer benefits, pension and insurance entitlements.

In some cases, JTL will need to process data to ensure that it is complying with its legal obligations. For example, JTL is required to check an employee’s entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled. For some roles it is necessary for JTL to carry out criminal records and Barred List checks to ensure that individuals are permitted to undertake the role in question.

In other cases, JTL has a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows JTL to: –

  • run recruitment and promotion processes;
  • maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights;
  • operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
    operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes;
  • operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled;
  • obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled;
  • operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that the organisation complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled;
  • ensure that tax and National Insurance are paid;
  • provide references on request for current or former employees;
  • respond to and defend against legal claims;
  • maintain and promote equality in the workplace such as making reasonable adjustments for individuals with disabilities; and
  • preventing fraud and dealing with legal claims made against us.

Where JTL relies on legitimate interests as a reason for processing data, it has considered if those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (such as those in relation to employees with disabilities and for health and safety purposes).

Where JTL processes other special categories of personal data, such as information about ethnic origin, sexual orientation, religion, trade union membership, political opinion, or disability, this must be processed in accordance with more stringent guidelines. Some of this information is used for the purposes of equal opportunities monitoring. Data that JTL uses for these purposes is anonymised or is collected with the express consent of employees, which can be withdrawn at any time. Employees are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

Most commonly, we will process special categories of data when the following applies:

  • you have given explicit consent to the processing;
  • we must process the data in order to carry out our legal obligations;
  • we must process data for reasons of substantial public interest;
  • you have already made the data public.

In all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

We will only seek criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to ensure that we meet our safeguarding obligations for employees who will come into
contact with students. Such information will only be retained according to the guidelines issued by the Disclosure and Barring Service.

Who has access to data?

Your information will be shared internally on a need to know basis, typically with members of the HR team, your line manager, managers in the business area in which you work and IT staff if access to the data is necessary for performance of their roles.

JTL shares your data with third parties in order to obtain references from other employers, and, where applicable, obtain necessary criminal records checks from the Disclosure and Barring Service. JTL may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.

JTL also shares your data with third parties that process data on its behalf, in connection with payroll, driving on company business, the provision of benefits, insurance and the provision of occupational health services.

JTL will not transfer your data to countries outside the European Economic Area.

How does JTL protect data?

In relation to your personal data, we will:

  • process it fairly, lawfully and in a clear and transparent way;
  • collect your data only for reasons that we find proper for the course of youremployment in ways that have been explained to you;
  • only use it in the way we have told you about;
  • ensure it is correct and up to date;
  • keep your data only for as long as we need it; and
  • process it in a way that ensures it will not be used for anything that you are not aware of or have not consented to (as appropriate) and which ensures that it will not be lost or destroyed.

JTL takes the security of your data seriously. JTL has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees with specific permission, in the performance of their duties.

Where JTL engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data. This is protected by the Information Sharing Agreement between JTL and the Third Party involved.

How long does JTL keep data?

JTL will hold your personal data for the duration of your employment. The periods for which your data is held after the end of employment are in line with our legal obligation regarding employment and taxation.

Your rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require JTL to change incorrect or incomplete data;
  • require JTL to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where JTL is relying on its legitimate interests as the legal ground for processing;
  • ask JTL to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation’s legitimate grounds for processing data; and
  • regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you would like to exercise any of these rights, please contact JTL’s Human Resources Director.

If you believe that JTL has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You have some obligations under your employment contract to provide JTL with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide JTL with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.

Certain information, such as contact details, your right to work in the UK and payment details, must be provided to enable JTL to enter a contract of employment with you.

If you do not provide other information, this will hinder JTL’s ability to administer the rights and obligations arising as a result of the employment relationship efficiently.

Data Controller: David Consterdine – Head of Quality Assurance and Audit
Data Protection Officer: Bal Heire – Head of IT Operations