Employee Fair Processing Notice

Howden Life & Health is part of the Hidden group of companies.

This document sets out how the companies within the Howden Group deal with personal data relating to their employees and job applicants.

We take data processing and data protection very seriously. We are committed to protecting the privacy and security of your personal data.

If you have any questions relating to data protection and the way we handle your personal data you should contact Jonathan Cumpstey our Data Protection Officer at jonathan.cumpstey@howdeninsurance.co.uk.

This notice does not form part of your employment contract and we may amend it at any time.

• name, gender, home address, date of birth, marital status, emergency contacts, salary information, bank and tax information, pensions, national insurance number and other benefits information;
• information you provide to us in your CV, covering letter, on your application form or during interview;
• nationality and passport information;
• date of hire, promotions, date and details of resignation/termination, work and educational history, criminal convictions (where relevant for your role), professional certificates and registrations;
• holiday records, performance appraisals, disciplinary and grievance investigations and outcomes;
• health details including sick pay, absence information and medical reports; and;
• voicemails, emails, correspondence and other work communications created, stored or transmitted by you using our systems.

Information relating to you comes from a number of sources. Much of it will be provided by you during the recruitment process and throughout your period of employment with us. Other personal information (such as references, appraisals and work related correspondence) is created or obtained during the course of your recruitment and/or employment.

We will only process your personal data for our legitimate interests to identify you including where relevant, as part of business processing, to manage all aspects of our employment relationship with you, to deal with payroll, benefits, legal and contractual matters and to maintain the security of our premises and systems. We may also process your personal data to validate your right to work in the UK and your suitability for employment with us.

We will also use your personal data: where we need to comply with a legal obligation; and where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We can also use your personal data in the following situations, which are likely to be rare: where we need to protect your interests (or someone else’s interests); and where it is needed in the public interest or for official purposes.

We do not use your personal data for marketing purposes.
We process your personal data in accordance with the data protection law that applies to the UK and European Union. We will only use your personal data 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 data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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.

"Special categories" of particularly sensitive personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data. We may process special categories of personal information in the following circumstances:. in limited circumstances, with your explicit written consent; where we need to carry out our legal obligations or exercise rights in connection with employment; and where it is needed in the public interest, such as for equal opportunities monitoring. Less commonly, we may process this type of data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

We don’t envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Your personal data may be disclosed to and processed by HR staff, line managers and other employees of the Company. All such persons are required to keep your personal data safe and secure.

We may also use various third parties to process your personal data as part of our employment. These may include outsourced payroll providers, external training providers, medical advisers, IT hosting and maintenance providers and, on occasion, lawyers. We will share your personal data 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. These third parties are carefully selected and under obligations to keep your personal data safe and secure. We will only provide these third parties the minimum personal data that they need and ensure that they only process it to the extent necessary to provide their limited services to us.

All of your personal data is processed within the UK. However, for the purposes of IT hosting and maintenance, this information is located on servers within the European Union. We have in place controls to ensure that your personal data is process responsibly and securely and not disclosed unnecessarily. Third parties are not given access to your personal data unless the law allows them to do so.

We have implemented procedures and technologies to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. It is held securely in our systems and accessible only by the HR team, managers and employees where appropriate.

Your personal data is kept throughout your employment with us. If you leave our employment, the majority of your personal data will be destroyed and erased from our systems but we will retain relevant personal data for six years in case there are any legal or tax issues. After that period we will retain only your full name, date of birth, job title and salary details so that we can track and analyse the company’s growth and development and in case you apply to re-join the company in the future. It will also allow us to reply to any reference request received.

Details of your data subject rights can be obtained from the Data Protection Officer.

If you suspect that any personal data that we hold about you is inaccurate or out of date, please let us know so that we can rectify it. In some circumstances you may be entitled to restrict the processing of your personal data or have your personal data erased. Please see the Data Subject Rights Guidance document for more information about this.

Details of your data subject rights can be obtained from the Data Protection Officer.

If you have any questions about data protection or are unhappy with the way we have handled your personal data please speak to the Data Protection Officer. You also have the right to lodge a complaint with the Information Commissioner’s Office.