Commercial Express is the Data Controller of the information held about you and is registered with the Information Commissioners Office under Registration Number Z7979314.
This policy applies to all employees, temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns, agents engaged with Commercial Express and job applicants.
Information we collect about you
We will collect personal information about you for the purposes of carrying out the contract of employment we have with you or in the case of potential employees, to assess your suitability for a role with Commercial Express.
Information may include your name, contact details, date of birth, information relating to health or criminal convictions, bank details, copy passport or other photographic ID, next of kin and emergency contact information, details of your education and qualifications, right to work information, conflict of interest information and performance management details.
During the recruitment process we may collect details about your previous employment, renumeration and benefits. Plus any additional information that you choose to tell us.
How is the information provided to us?
Most of the personal information we hold about you is received directly from you, however we may collect your data in the following ways:
- From you, either in person, by email or other correspondence, or by telephone or video recording
- From recruitment agencies
- From previous employers (referees)
- From occupational health services (via referrals)
- From HMRC
- From providers of staff benefits (except where data collected by providers is confidential)
How will we use your data?
Where we process your personal information, we do so on the basis that the processing is necessary for the purposes of the performance of a contract with you, for compliance with legal obligations which the company is subject to, or where we have legitimate interests to process that data, for example during the recruitment process.
We may on occasion obtain your consent to use content featuring you (such as photographs or video), your name, biography or testimonials for the purposes of social media, website articles and pages, or other marketing purposes. You should be aware that it’s not a condition or requirement of your employment to agree to any request for consent from Commercial Express. Where consent is given, it may be withdrawn by you at any time, however this will not impact on any other lawful basis for processing relied on by the company.
We will use your personal information:
- To provide payment of your salary, overtime, bonus, pension, expenses and any other employment related benefits
- To administer statutory and contractual leave entitlements such as holiday, maternity or paternity leave
- To ensure your health and wellbeing needs are being catered for, and to understand where reasonable adjustments may need to be made
- To promote equal opportunities, diversity and inclusion
- To process professional memberships where applicable
- For performance management purposes, for example conducting, 1-2-1 meetings, mid and end of year appraisals, probationary reviews, identifying training needs
- To satisfy legal obligations such as PAYE requirements, Health & Safety Laws, Regulatory Requirements
- Where applicable, for disciplinary matters or grievances at work
- To assess compliance with processes, procedures and regulatory matters, for example Quality Assurance and Compliance Monitoring audits
- To contact you in the event of a Business Continuity Event
- For promotional purposes (with consent)
- To assess your suitability for a job vacancy
- To facilitate future reference requests
- To meet our legal obligations where required, for example where we are required to disclose information under a court order or statutory requirement
Who will we share your information with?
As a necessary part of fulfilling your employment contact, meeting our legal or contractual obligations, and to facilitate the operation of the business, we may need to disclose your personal data to other third parties. These include:
- Benefit Providers – Pension, Death in Service, Health Plans, Occupational Health
- Payroll Services
- First Aiders
- Computer bureau/Software Houses
- Insurers, other Insurance Intermediaries
- Government databases or Credit agencies
- Employment screening providers
We have appropriate contracts with all third parties and ensure they have appropriate data security policies in place.
Where we are obliged to do so, we may also be required to provide your information to regulatory authorities, the Police and / or other law enforcement bodies. If required in order to meet our legal or regulatory obligations, we may transfer your personal data to destinations outside the European Economic Area (EEA). Where we do, we will ensure that it is treated securely and in accordance with the legislation.
How do we store your data?
We have appropriate security measures and an IT security policy in place to protect your information and prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way.
How long will we retain your data for?
Your data will not be retained for longer than is necessary and will be managed in accordance with our record retention policy. In most cases the period will be for a maximum of 7 years after termination of a service or contract. In certain circumstances we may be required to retain data for a longer period due to business, legal or regulatory requirements. We will only do this where we have identified a lawful basis for doing so.
Recruitment records for unsuccessful candidates will usually be retained for no longer than 12 months, however, as part of the recruitment process and with candidate consent, we may keep candidates’ information on file for the purpose of any future job opportunities that Commercial Express considers may be suitable for the candidate.
We operate secure deletion or destruction of records using the following methods:
- Manual review and deletion of electronic records in shared folders
- Automated bulk deletion for email records
- Destruction of paper-based records via secure shredding and disposal facility
Your data protection rights
Data Protection Legislation provides you with the following legal rights in relation to the processing of your personal data:
- The right to request a copy of the personal data we hold about you
- The right to request that your personal information is rectified if you believe it is inaccurate or incomplete
- The right to request erasure of your personal information under certain circumstances
- The right to restrict processing of your personal information under certain circumstances
- The right to request that we transfer your data to another organisation or directly to you, under certain conditions
- The right to object to certain processing, including for the purposes of direct marketing
- The right to be provided with information in relation to automated decision-making and profiling
- You also have the right to lodge a complaint with the Information Commissioner’s office at any time if you are concerned about the way in which we handle your data
If you have a query or concern
Existing employees should contact HR or Risk & Compliance in the first instance.
External Contractors, Ex-employees or job applicants can contact us using the following details:
Email at: Agency@commercialexpress.co.uk
Phone: 01384 473021
Or by writing to us at: Commercial Express, B1 Custom House, The Waterfront, Level Street, Brierley Hill, DY5 1XH
You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk