Employee Privacy Policy

APSS collects and processes personal data relating to its employees to manage the employment relationship.  APSS is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does APSS collect?

APSS collects and processes a range of information about you. This includes:

  • your name, address and contact details, including email address and telephone number, date of birth and gender;
  • the terms and conditions of your employment;
  • details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with APSS;
  • information about your remuneration, including entitlement to benefits such as pensions;
  • details of your bank account and national insurance number;
  • information about your marital status, next of kin, dependants and emergency contacts;
  • information about your nationality and entitlement to work in the UK;
  • information about your criminal record;
  • 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 performance reviews, training you have participated in, performance improvement plans and related correspondence;
  • information about medical or health conditions, including whether or not you have a disability for which APSS needs to make reasonable adjustments.

APSS collects this information in a variety of ways.  For example, data is collected through application forms or CVs; 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; from correspondence with you; or through interviews, meetings or other assessments.

APSS collects personal data about you from third parties, such as references supplied by former employers.

Data is stored in a range of different places, including in your personnel file, in APSS’ HR and Payroll management systems and in other IT systems (including APSS’ email system).

Why does APSS process personal data?

APSS needs to process data to enter into an employment contract with you and to meet its obligations under your employment contract.  For example, it needs to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer benefit entitlements.

In some cases, APSS needs to process data to ensure that it is complying with its legal obligations.  For example, it 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. 

In other cases, APSS has a legitimate interest in processing personal data before, during and after the end of the employment relationship.  Processing employee data allows APSS 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 APSS 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 effective general HR and business administration;
  • provide references on request for current or former employees;
  • respond to and defend against legal claims.

Where APSS relies on legitimate interests as a reason for processing data, it has considered whether or not 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).

Who has access to data?

Your information will be shared internally, including with members of the HR and payroll, 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.

APSS shares your data with third parties in order to obtain pre-employment references from other employers. 

APSS also shares your data with third parties that process data on its behalf in connection with the provision of benefits and the provision of occupational health services.

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

How does APSS protect data?

APSS takes the security of your data seriously.  APSS 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 in the performance of their duties.

Where APSS 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.

For how long does APSS keep data?

APSS 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 set out in the Data Protection section in the Employee Handbook.

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 APSS to change incorrect or incomplete data;
  • require APSS 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 APSS is relying on its legitimate interests as the legal ground for processing; and
  • ask APSS to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override APSS’ legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact the Sarah Crookes, HR Director.  You can make a subject access request by completing APSS’ form for making a subject access request (See Data Protection section in Employee Handbook).

If you believe that APSS 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 APSS 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 APSS 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, have to be provided to enable APSS to enter a contract of employment with you.  If you do not provide other information, this will hinder APSS ability to administer the rights and obligations arising as a result of the employment relationship efficiently.