Workforce Privacy Policy

EUROMONITOR INTERNATIONAL

WORKFORCE DATA PRIVACY NOTICE 

 

Last Updated: August 2024

1.           ABOUT THIS DATA PRIVACY NOTICE

1.1 This notice is designed to provide information on how Euromonitor International (referred to as “we”, “us” or “our”) processes the personal data of its workforce (referred to as “you” or “your”) in accordance with the General Data Protection Regulation and, when enacted, the Data Protection Act 2018 (together referred to as the “GDPR”). This notice applies to current and former members of our workforce.

1.2 As a “data controller”, we are responsible for deciding how we process personal data about you. We take your privacy seriously and we are fully committed to protecting your personal data at all times. We will only process your personal data in accordance with applicable data protection laws, adhering to the principles (as applicable) contained in the GDPR.

1.3 This notice does not form part of your contract of employment and we may amend it at any time to reflect any changes in the way in which we process your personal data. We will provide you with a new privacy notice when we make any substantial updates, and we may also notify you in other ways from time to time about the processing of your personal data.

1.4         Our Data Protection Manager (“DPM”) is responsible for ensuring that this privacy notice is maintained. Please contact DataProtectionOfficer@euromonitor.com with any queries.

 

2.           THE KIND OF INFORMATION WE HOLD ABOUT YOU

2.1 “Personal data” is any information about a living individual from which they can be identified such as name, ID number, location data, any online identifier, or any factor specific to the physical, physiological, genetic, mental, economic or social identity of that person. It does not include data where any potential identifiers have been removed (anonymous data) or data held in an unstructured file.

2.2 There are “special categories” of more sensitive personal data which are more private in nature and therefore require a higher level of protection, such as genetic data, biometric data, sexual orientation, race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and health.  

2.3 When we refer to “processing”, this means anything from collecting, using, storing, transferring, disclosing, altering or destroying personal data.      

 

3.           RECEIVING YOUR PERSONAL DATA

3.1 We may obtain personal data and/or special category personal data about you from third party sources, such as recruitment agencies, job boards, online recruitment platforms, recruitment assessment centres, occupational health professionals and background check providers. Where we receive such information from these third parties, we will only use it in accordance with this notice. In some cases, they will be acting as a controller of your personal data and therefore we advise you to read their privacy notice and/or data protection policy.

 

4.           HOW WE USE YOUR PERSONAL DATA  

4.1 We process your personal data for various reasons, relying on a variety of different bases for lawful processing under data protection law, as set out below. 

4.1.1     To comply with our legal obligations. This may include:

•  eligibility to work in the Country as required by immigration laws, such as passport and visa documentation;

•  payroll records, social security, child maintenance, student loans and national insurance information to comply with social security and Tax requirements;

•  information in relation to legal claims made by you or against you, in order to comply with court processes and court orders;

•  information relating to the occurrence, investigation or prevention of fraud, such as through a whistleblowing complaint; and

•  pension and retirement benefits to comply with pension legislation; 

4.1.2 To prepare for and to perform the contract of employment you have entered in to with us.  This may include:

•  formal identification documentation relating to you, such as a passport or driving licence, to verify your identity (including your date of birth);

•  Basic personal details for general administration and management purposes

•  Fob data including entry and exit times in order to manage and provide you with access to our buildings;

•  your contact details such as your name, address, telephone number and personal email address which will be used to communicate with you on employment matters during your employment;

•  bank details which are used to send/receive funds to/from you such as payment of your salary, bonus, commission, sick pay, statutory maternity/paternity/ adoption/shared parental leave pay, or to make or repay loans or advances of salary; 

•  information relating to the enrolment or renewal of your employment benefits including pension, private health care, income protection insurance and life assurance] in order to provide you with these benefits; and

•  details of the terms and conditions of your employment.

4.1.3      To pursue our (or a third party’s) legitimate interests¹ as a business.  This may include:

•  training records, appraisals, performance reviews, check ins  and 1:1 meeting notes about you in order to assist/assess your career development and training needs and/or to ensure that you are properly managed and supervised;

•  information relating to the performance of your employment duties,  such as disciplinary records, as this is relevant to your ability to carry out your job and for us to assess and identify areas in which we may need to help you improve; 

•  information relating to the performance of your duties may also be used  to conduct an investigation if circumstances warrant it and to take appropriate action either for conduct or capability reasons in accordance with our Disciplinary Policy;

•  information relating to any grievance process involving you, in order that an investigation may be conducted and appropriate action taken (if any) in accordance with our Grievance and Disciplinary Policies; 

•  management reports (including statistical and audit information) to ensure workplace efficiencies are maximised;

•  health, safety and environmental information, including records to ensure that we are complying with relevant policies and procedures. This allows us to implement any training where applicable;

•  work related contact details on our intranet and/or internal systems including the Company Organisation Chart to facilitate efficient communication within the business;

•  work related contact details and work files to provide access and to feed into external software and tools for productivity, efficiency and to carry out daily duties;

•  Name, email, job title, email address and other information provided by yourself where you raise a ticket, in order to resolve any issues you are facing and/or grant access to various internal and/or external systems/tools.

•  voicemails, emails, correspondence and other work-related communications created, stored or transmitted by you using our computer or communications equipment for the purposes of the efficient management of the business in accordance with our IT Usage Policy;

•  absence records and details including holiday records, appointments, sick records, jury service, maternity, paternity, adoption and parental leave in order to monitor attendance levels and to comply with our policies;

•  CCTV and swipe card access records from our offices which are in place for the protection of our property;

•  Entry and exit times to facilitate our occasional employee monitoring activities to ensure compliance with flexible and hybrid working policies which are available on the Intranet

•  Travel documentation to facilitate business travel where required.

•  Basic personal information including transaction data in order to provide workplace giving, volunteering, corporate granting and employee engagement services to facilitate our Corporate Social Responsibility (CSR) activities

•  Contact details for the promotion of our business activities

4.1.4     Where you have consented to specific processing. This may include:

•  information disclosed to a third party agency relating to your pay details for the purposes of providing tenancy references;

•  information disclosed to a mortgage provider relating to your employment history and pay details for the purposes of a mortgage application; and

•  information disclosed to a prospective future employer relating to your employment details for the purposes of providing a reference.

4.1.5 Where it is in your vital interests. This may include information about allergies or any medical conditions so as to prevent any unnecessary accidents, and advise medical professionals in the event of an emergency. 

4.2           Where you have consented to specific processing of your personal or special categories data, you have the unequivocal right to withdraw your consent at any time by indicating your withdrawal in a written format to the Global HR Director or the DPM. 

4.3           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.

 

5.           HOW WE USE YOUR SPECIAL CATEGORY PERSONAL DATA  

5.1 We also collect, store and use your special category personal data for a range of reasons, relying on a variety of different bases for lawful processing under the GDPR.

5.1.1 To enable us to perform our legal obligations in respect of employment, social security, and social protection law. This may include:

•  information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws;

•  information gathered as part of a whistleblowing investigation; 

•  information relating to you involving allegations of unlawful discrimination, in order that an investigation may be conducted and appropriate action taken (if any) under our Disciplinary or Grievance Policies; and

• health information to assess and/or to comply with our obligations under employment, equal opportunities and health and safety legislation (for example a requirement to make reasonable adjustments to your working conditions); and

5.1.2 For occupational health reasons or where we are assessing your working capability, subject to appropriate confidentiality safeguards. This may include:

•  information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits;

•  sickness absence records, such as statement of fitness to work, reasons for absence and self-certification forms; and

•  records of return to work interviews/meetings.

5.1.3 Where it is needed for statistical purposes in the public interest, such as for equal opportunities monitoring. To ensure meaningful equal opportunities monitoring and reporting, we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, and your sexual life or orientation. 

5.1.4 To establish, defend or exercise legal claims in an employment tribunal or any other court of law.

 

6                INFORMATION ABOUT CRIMINAL CONVICTIONS

6.1 We do not envisage that we will hold information about criminal convictions.  

 

7            AUTOMATED DECISION MAKING / PROFILING

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

 

8            DATA SHARING

8.1 We may share your personal data and special category personal data internally. In particular, it may be shared with: HR employees involved in the recruitment process, employee relations and/or administration of your employment; line managers; consultants; advisers; or other appropriate persons who we shall make you aware of from time to time.

8.2  We may share your personal data and special category personal data with third  parties, agents, subcontractors and other organisations (as listed below) where it is  necessary to administer the working relationship with you or where we have a  legitimate interest in doing so:

Category           of               personal information	Recipient/relationship to us	Purpose of disclosure
All          personal               information collected	IT service providers (service providers)	To support, maintain and host our information systems, including the software and hardware infrastructure required for it to operate/be accessible online and to keep a backup of your personal information. We use online IT service providers to manage and resolve tickets raised and to provide contract execution services.   We use software providers to store our employee data to ensure that we can manage all workforce in a single location.
Name, contact details, date of birth and health data	Employee benefits providers	For employee benefits to be provided and premiums to be calculated
All          personal               information collected	Our       legal     and       other professional advisers.	To provide us with advice in relation to our business, including our legal, financial and other obligations and claims
Name, contact details,  start and end dates of employment and health data	Our insurance providers	For premiums to be calculated and insurance cover to be provided
Name, contact details, start and end dates of employment, date of birth, pay, bank and absence details	Payroll and pension providers	For pay to be processed and pension benefits to be provided
Job role and health data	Occupational health providers	For working capacity of worker to be assessed
Name, job title, email address, work number, call transcripts, files	IT service providers e.g. Microsoft co-pilot and Microsoft Teams Premium     Managed Service Providers	To facilitate employees in improving the quality and efficiency of their daily tasks.     To provide us with advice in relation to our data and the quality of such data. To assist in obtaining the most value out of the software/tools that the business has/will purchase.
Name, email address	Service/software/tool providers   AI tool/software providers	To allow employees to access the various services/tools required to carry out their role.
Travel documentation	Business travel service provider	To facilitate business travel for employees where required.

 

 8.3 When we disclose your personal data to third parties as listed above, we only disclose to them any personal data that is necessary for them to provide their service. We have contracts in place with these third parties in receipt of your personal data requiring them to keep your personal data secure and not to use it other than in accordance with our specific instructions.

8.4  All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. 

8.5 We may also share your personal data and special category personal data with other third parties for other reasons. For example, in the context of the possible sale or restructuring of the business; to provide information to a regulator; or to otherwise comply with the law. To comply with our legal obligations we may share your data with the following, all of whom are obliged to have adequate policies/procedures in place in relation to data security:

•            HMRC, or home Country equivalent, for tax purposes;

•            Home Office for immigration purposes; 

•            student loan agencies to ensure that appropriate reductions are made from your salary and;

•  third parties such as mortgage providers, property rental providers or prospective future employers (as stated at 4.1.4) with your consent