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Forward Connect privacy notice

As an employer The Forward Trust (Forward) must meet its contractual, statutory and administrative obligations. We are committed to ensuring that the personal data of our employees is handled in accordance with the principles set out in the Information Commissioner’s Office (ICO) Guide to Data Protection.

This privacy notice tells you what to expect when Forward collects personal information about you. It applies to (includes but not limited to) all employees, ex-employees, agency staff, contractors, casual workers.  However the information we will process about you will vary depending on your specific role and personal circumstances.

Forward is the controller for this information unless this notice specifically states otherwise. Our Data Protection Officer is Lorna Cox you can contact her at lorna.cox@forwardtrust.org.uk

This notice should be read in conjunction with our organisation privacy notice and our other corporate policies and procedures.

How we get your information

We get information about you from the following sources:

  • Directly from you.
  • From an employment agency.
  • From referees, either external or internal.
  • From security clearance providers.
  • From Occupational Health and other health providers.
  • From Pension administrators and other government departments, for example tax details from HMRC.
  • From providers of staff benefits.
Personal data we process and why

We process the following categories of personal data:

Information related to your employment:

We use the following information to carry out the contract we have with you, provide you access to business services required for your role and manage our human resources processes.

  • Personal contact details such as your name, address, contact telephone numbers (landline and mobile) and personal email addresses.
  • Your date of birth, gender and NI
  • A copy of your passport or similar photographic identification and / or proof of address
  • Marital status.
  • Next of kin, emergency contacts and their contact
  • Employment and education history including your qualifications, job application, employment references, right to work information and details of any criminal convictions that you
  • Location of employment.
  • Details of any secondary employment, political declarations, conflict of interest declarations or gift declarations.
  • Security clearance details including basic checks and higher security clearance details according to your job.
  • Any criminal convictions that you declare to
  • Your responses to staff surveys if this data is not

Information related to your salary, pension and loans:

We process this information for the payment of your salary, pension and other employment related benefits. We also process it for the administration of statutory and contractual leave entitlements such as holiday or maternity leave.

  • Information about your job role and your employment contract including; your start and leave dates, salary (including grade and salary band), any changes to your employment contract, working pattern (including any requests for flexible working).
  • Details of your time spent working and any overtime, expenses or other payments claimed, including details of any loans such as for travel season
  • Details of any leave including sick leave, holidays, special leave
  • Pension details including membership of both state and occupational pension schemes (current and previous).
  • Your bank account details, payroll records and tax status information.
  • Details relating to Maternity, Paternity, Shared Parental and Adoption leave and pay. This includes forms applying for the relevant leave, copies of MATB1 forms/matching certificates and any other relevant documentation relating to the nature of the leave you will be

Information relating to your performance and training:

We use this information to assess your performance, to conduct pay and grading reviews and to deal with any employer / employee related disputes. We also use it to meet the training and development needs required for your role.

  • Information relating to your performance at work eg probation reviews, Quarterly Line Management Review’s, annual reviews, promotions, flexible working requests, career break requests etc.
  • Grievance, and dignity at work matters (Bullying and Harassment) and investigations to which you may be a party or
  • Bullying and harassment claim
  • Disciplinary records and documentation related to any investigations, hearings and warnings/penalties
  • Whistleblowing concerns raised by you, or to which you may be a party or
  • Information related to your training history and development needs.

 

Information relating to monitoring:

We may use this information to assess your compliance with corporate policies and procedures and to ensure the security of our premises, IT systems and employees.

 

Information relating to your health and wellbeing and other special category data:

We use the following information to comply with our legal obligations and for equal opportunities monitoring. We also use it to ensure the health, safety and wellbeing of our employees.

  • Health and wellbeing information either declared by you or obtained from health checks, eye examinations, occupational health referrals and reports, sick leave forms, health management questionnaires or fit notes i.e. Statement of Fitness for Work from your GP or hospital.
  • Accident records if you have an accident at
  • Details of any desk audits, access needs or reasonable
  • Information you have provided regarding Protected Characteristics as defined by the Equality Act and s.75 of the Northern Ireland Act for the purpose of equal opportunities monitoring. This includes racial or ethnic origin, religious beliefs, disability status, and gender identification and may be extended to include other protected characteristics.
Lawful basis for processing your personal data:

Depending on the processing activity, we rely on the following lawful basis for processing your personal data under the GDPR:

  • Article 6(1)(b) which relates to processing necessary for the performance of a contract.
  • Article 6(1)(c) so we can comply with our legal obligations as your employer.
  • Article 6(1)(d) in order to protect your vital interests or those of another person.
  • Article 6(1)(e) for the performance of our public task.
  • Article 6(1)(f) for the purposes of our legitimate

Special category data:

Where the information we process is special category data, for example your health data, the additional bases for processing that we rely on are:

  • Article 9(2)(b) which relates to carrying out our obligations and exercising our rights in employment and the safeguarding of your fundamental
  • Article 9(2)(c) to protect your vital interests or those of another person where you are incapable of giving your
  • Article 9(2)(h) for the purposes of preventative or occupational medicine and assessing your working capacity as an
  • Article 9(2)(f) for the establishment, exercise or defence of legal claims.

In addition we rely on processing conditions at Schedule 1 part 1 paragraph 1 and Schedule 1 part 1 paragraph 2(2)(a) and (b) of the DPA 2018. These relate to the processing of special category data for employment purposes, preventative or occupational medicine and the assessment of your working capacity as an employee. Please see our Staff Handbook provides further information about this processing.

Criminal convictions and offences

We process information about staff criminal convictions and offences. The lawful basis we rely to process this data are:

  • Article 6(1)(e) for the performance of our public task. In addition we rely on the processing condition at Schedule 1 part 2 paragraph 6(2)(a) of the DPA 2018
  • Article 6(1)(b) for the performance of a contract. In addition we rely on the processing condition at Schedule 1 part 1 paragraph 1 of the DPA 2018.

Our Staff Handbook provides further information about this processing.

 

How long we keep your personal data

For information about how long we hold your personal data, see our Records Management Policy.

Data sharing

In some circumstances, such as under a court order, we are legally obliged to share information. We may also share information about you with third parties including government agencies and external auditors. For example, we may share information about you with HMRC for the purpose of collecting tax and national insurance contributions.

Your rights in relation to this processing

As an individual you have certain rights regarding our processing of your personal data, including a right to lodge a complaint with the Information Commissioner as the relevant supervisory authority.

For more information on your rights, please see the ICO guidance on ‘Your rights as an individual’.

Transfers of personal data

We don’t routinely transfer staff personal data overseas but when this is necessary we ensure that we have appropriate safeguards in place.

Further information

Personnel files:

Physical and electronic records are held for each member of staff. Your hard copy personnel file is stored in the archives. The company which we use is Restore PLC. A link to their privacy notice can be found in Annex A. We also keep electronic records on Forward Trust OneDrive / Office 365.

You can request your personnel file by submitting an subject access request to forwardfeedback@forwardtrust.org.uk. You can also make a verbal request for your information. You will not be able to take away your physical file but if requested you can have a copy of your file.  We will consult internally with members of staff who might hold personal data about you.

Staff surveys:

The data collected from staff surveys is held in the cloud based platform Survey Monkey. Any data collected by Survey Monkey is stored on their servers which are located in the US, Ireland and Canada. A link to their privacy notice can be found in Annex A. The data is only available to a small number of HR staff.

Most survey questions require quantitative responses, however some free text boxes are included. We would advise you not to share identifiable information about yourself in these boxes if you wish to remain anonymous. When appropriate we will also provide ‘just in time’ privacy information regarding specific surveys.

 

Whistleblowers:

Forward Trust has a policy and procedure in place to enable its current staff and ex-employees to have an avenue for raising concerns about malpractice.
If you wish to raise a concern please refer Freedom to Speak Up – Whistleblowing Policy. Information in this context is processed by us because it is necessary for our compliance with our legal obligations under the Public Interest Disclosure Act 1998 and The Public Interest Disclosure (Northern Ireland) Order 1998.

Although every effort will be taken to restrict the processing of your personal data and maintain confidentiality whether this is possible will be dependent on the nature of the concern and any resulting investigation.

Equal opportunities monitoring:

Equal opportunities information provided by job applicants is attached to the relevant application when you apply for a role at Forward Trust.

This information is not made available to any staff outside our HR team (including hiring managers) in a way which can identify you. This information is anonymised after six months and retained for reporting purposes only.

 

Workforce Development and Planning:

Our HR Team uses an online learning platform called Charity Learning Consortium for the facilitation of its work related courses. A link too their privacy notices can be found in Annex A. We will share some information about you with these providers both prior to you joining Forward Trust and during your employment to ensure you have the necessary access to complete training required for your role.

We will also share information about you with our training providers. For example this will include information such as your name, contact details and job role.

 

Occupational health:

During your employment you may be referred to occupational health following a request to HR by you or your line manager. This may result in a face-to-face consultation, a telephone appointment with an occupational healthcare professional and/or a medical report from a GP or specialist.

We use Medigold to provide our occupational health service. The information you provide will be held by Medigold, who will provide us with a report with recommendations as appropriate. Medigold only process data within the EU. A link to their privacy notice can be found in Annex A.

 

Health Plan:

If you consent for us to do so we will pass on your details to Simply Health which provides you with Health Insurance. Simply Health do use third party processors and some may be based outside of the EU, however they do ensure that the same level of protection of your data either through contracts with third parties, transferring information under the Privacy Shield or ensuring that they transfer data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. A link to their privacy notice can be found in Annex A.

 

Employee Self Service HR System / Payroll:

Forward Trust use CascadeHR (IRIS Software Group Limited) for employee information and payroll. Cascade allows the employee to enter their own personal information. All information remains in the UK on UK data centres. A link to their privacy notice can be found in Annex A.

Monitoring of staff:

All of our ICT systems are auditable and can be monitored, though we don’t do so routinely. We are committed to respecting individual users’ reasonable expectations of privacy concerning the use of our ICT systems and equipment.

However, we reserve the right to log and monitor such use in line with our Information Technology and Communications Policy.

Any targeted monitoring of staff will take place within the context of our disciplinary procedures.

Financial monitoring:

We use a financial accounting system Sage to log every financial transaction. This includes any transactions or loans made by or to staff. If an outstanding debt by a member of staff is highlighted via this process, Forward Trust will use this information to take steps to recover the outstanding amount.

 

Security clearance:

An enhanced Disclosure and Barring Service (DBS) check with adult and child barring is required for certain teams. Employees upload their information onto the gov.uk website which is provided by the Government Digital Service. A link to their privacy notice can be found in Annex A.

 

Identification passes:

All staff are all issued with an ID pass that displays their name, job title and photograph. Staff pass details (names, numbers and photographs) are held on a standalone machine controlled by Facilities and can only be accessed by a restricted number of people.

 

Pension:

Our pension provider is Aviva. They store your information in Europe. They do have use third parties that process information on their behalf however they ensure that they obtain contractual commitments and assurances and they only transfer personal information to countries which are recognised as providing an adequate level of legal protection. A link to their privacy notice can be found in Annex A.

 

Legal advice:

Our legal advisors are Radar Legal Services. They may transfer data out of the EU however they will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. A link to their privacy notice can be found in Annex A.

 Reports to General Medical Council, Nursing and Midwifery Council and British Association Counselling and Psychotherapy:

If concerns are raised or observed regarding your practices then we may need to share your information with the relevant registration body.

Disclosures under the Freedom of Information Act

As have public authority duties we receive information requests under the Freedom of Information Act (2000) about our staff and we must consider whether to disclose staff information (including agency and temporary staff) in response to these requests.

We will normally disclose work-related information about staff in a public- facing role. We may also disclose information about staff members whose work is purely administrative if their names are routinely sent out externally.

It is less likely that information about those who do not deal directly with the public in an operational capacity will be disclosed. The Executive Team will have more information disclosed about them, such as photographs and biographical detail, due to their position at Forward Trust.

We will consider withholding information if we think that the rights and safety of our staff, irrespective of grade or position will be compromised.

The type of information provided will only concern your professional life at the Forward Trust. We will not disclose non-work related personal or special category data.

We will consult with you prior to deciding whether to disclose any information that we consider would not be within your reasonable expectations.

Before you begin working at Forward, contact HR if you need to make us aware of a specific reason why your information cannot be provided as part of a disclosure. At any later point, if you have any concerns about information being released you need to inform us of this fact.

 

Requests for references:

If you leave, or are thinking of leaving, we may be asked by your new or prospective employers to provide a reference. For example we may be asked to confirm the dates of your employment or your job role. If you are still employed by us at the time the request for a reference is received we will discuss this with you before providing this.

Annex A – Data Processors

Data processors are third parties who provide certain parts of our staff services for us. We have contracts in place with them and they cannot do anything with your personal information unless we have instructed them to do so. Our current data processors are listed below.

Data Processor Purpose Privacy Notice
CascadeHR Employee Self Service HR System https://cascadehr.co.uk/privacy-cookies/
Simply Health Health Insurance Providers https://www.simplyhealth.co.uk/about-us/privacy
Medigold Occupational Health Providers http://www.medigold-health.com/Home/PrivacyNoticeOccupationalHealth
Charity Learning Consortium Online eLearning Platform https://charitylearning.org/data-processing-policy/
iCMS Recruitment Portal https://www.icims.com/gc/data-security-privacy-statement/
Radar Forward Trust Legal Advisors https://www.rradar.com/privacy-policy
Cycle to work scheme Employee cycle benefit https://www.ourprivacycommitments.com/
Aviva Pension Scheme https://www.aviva.co.uk/services/about-our-business/products-and-services/privacy-policy/
Disclosure and Barring Service DBS Checks https://www.gov.uk/help/privacy-notice
Restore Plc Document Storage https://restoreplc.com/GDPR-Data-Processing-Policy
Survey Monkey Online Staff Surveys https://www.surveymonkey.co.uk/mp/legal/privacy-policy/
Annex B – Detailed Guidance on our Lawful Basis for Processing
Personal Data Being Processed Lawful Basis for Processing
Carry out the employment contract that we have entered into with you e.g. using your name, contact details, education history, information on any disciplinary, grievance procedures involving you Performance of the contract
Ensuring you are paid Performance of the contract
Ensuring tax and National Insurance is paid Legal obligation
Carrying out checks in relation to your right to work in the UK Legal obligation
Making reasonable adjustments for disabled employees Legal obligation
Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion Our legitimate interests
Making decisions about salary and other benefits Our legitimate interests
Ensuring efficient administration of contractual benefits to you Our legitimate interests
Effectively monitoring both your conduct, including timekeeping and attendance, and your performance and to undertake procedures where necessary Our legitimate interests and possibly explicit consent if special category data
Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective  correspondence can be achieved and appropriate contact points in the event of an

emergency are maintained

Our legitimate interests
Implementing grievance procedures Our legitimate interests and possibly explicit consent if special category data
Assessing training needs Our legitimate interests
Implementing an effective sickness absence management system including monitoring the amount of leave and  subsequent actions to be taken including the making of reasonable adjustments Our legitimate interests and possibly explicit consent if special category data
Gaining expert medical opinion when making decisions about your fitness for work Our legitimate interests and possibly explicit consent if special category data
Managing statutory leave and pay systems such as maternity leave and pay etc. Our legitimate interests
Business planning and restructuring  exercises Our legitimate interests
Dealing with legal claims made against us Our legitimate interests and possibly explicit consent if special category data
Preventing fraud Our legitimate interests
Ensuring our administrative and IT systems are secure and robust against unauthorised access Our legitimate interests
Passing information onto Simply Health Consent
Sharing data / information with Radar / Company Solicitors Where the Trust seeks and Radar provides legal advice, all correspondence between the parties is covered by ‘Legal Professional Privilege’ and is therefore exempt from disclosure to any person/organisation including the data subject, under a paragraph 19 of Schedule 2 to the Data Protection Act 2018 exemption.
Reports to General Medical Council, Nursing and Midwifery Council and British Association Counselling and Psychotherapy Vital Interests