People Services & OD

The London Borough of Hounslow is committed to protecting and respecting your privacy. Through this Privacy Notice we have sought to be as transparent as possible and fully explain how your personal data is held and processed.

This privacy notice applies to services provided by People Services & OD and tells you what to expect us to do with your personal information.

If you have any questions about this privacy notice or any concerns about how we process your data, please contact peoplesupport@hounslow.gov.uk. The privacy notice will continue to be monitored and updated. You are advised to check this page from time to time.

What type of information we have

We currently collect and process a range of information about you. This information will vary depending on whether you are an applicant for a post with Hounslow Council, a direct employee or worker (including agency, interim consultants). The information may include:

For applicants:

your name, address and contact details, including email address and telephone numbers
details of your qualifications, skills, experience and employment history
information about your remuneration, including entitlements to benefits such as pensions
whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process
information about your entitlement to work in the UK
information about your criminal records
equality and diversity monitoring information, including information about your age, gender, ethnic origin, sexual orientation, health, and religion or belief.

For employees:

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 the council and dates of continuous service
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, and emergency contacts
information on dependants where required for pension purposes, childcare vouchers or other benefits
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, other authorised 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
details of public concerns or other complaints raised by you
assessments of your performance, including appraisals, performance reviews, performance improvement plans and related correspondence
information relating to learning and development activities both for performance of employment or personal development
information about medical or health conditions, including where necessary details of vaccinations related to your employment
information on whether or not you have a disability for which the council needs to make reasonable adjustments or where reasonable adjustments have been made and related correspondence
details of trade union membership, where subscription deductions are made by payroll;
equality and diversity monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
Information relating to arrangements for leaving the organisation.

How do we get your information?

Most of the personal information we process is provided to us directly by you. This may be when you submit forms or correspond with us by post, phone, email or you may provide personal data when you sign up to enquire about council provided service, request information, complete a survey, give us feedback or make a complaint.

Your data is therefore collected through application forms and 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 (such as application forms, benefit nomination forms); from correspondence with you; or through interviews, meetings or other assessments.

In some cases, the council collects and or receives personal information about you from third parties, such as employment references supplied by former employers, information on your health from medical professionals such as your GP, information from employment background check providers, information from credit reference agencies and information from Disclosure and Barring checks permitted by law.

The above personal information is collected in order to enter into or to maintain an employment relationship and to facilitate your performance and development.

If it is not disproportionate or prejudicial, we’ll contact you to let you know we are processing your personal information.

Our Lawful basis for processing your information

The lawful basis we rely on for processing this information is:

Legal Obligation
Contract
Consent

You can remove your consent at any time by contacting us via email: peoplesupport@hounslow.gov.uk

The Council may process Special Categories of Personal Data and Criminal Convictions Data for the following employment purposes:

assessing your fitness to work
complying with health and safety obligations
complying with the Equality Act 2010
checking your right to work in the UK
checking DBS clearance (if relevant to your post)
checking criminal convictions (where relevant your post)
verifying vaccine status (if relevant to your post) and
verifying that candidates are suitable for employment or continued employment

If the information you provide us contains special category data, such as health, religious or ethnic information, the legal basis we rely on to process is:

Legal obligation
Contract

The processing will be in accordance with the substantial public interest conditions set out in Schedule 1, Part 2 of the Data Protection Act 2018 and the condition for processing employment, social security and social protection data, under Schedule 1, paragraphs 1(1) (b) and 5.

Why we need your information (purposes of processing)

We process your data to enter into an employment contract with you and to meet our obligations under your employment contract. For example, we need to process your data to provide you with an employment contract, to pay you in accordance with your employment contract, to administer benefit and pension entitlements and to support your development and progression.

The personal data we collect will be used for the purpose of entering and retaining an employment contract and relationship which enables you to grow and develop. Information will be used for the following purposes:

to ensure that we are complying with our legal obligations:

to check your entitlement to work in the UK
to deduct tax
to comply with health and safety laws
to enable you to take periods of leave to which you are entitled.
to carry out criminal records checks where required, to ensure that individuals are permitted to undertake the role in question
to comply with statutory reporting requirements

where there is a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows the council to:

run recruitment 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 and other investigations e.g. complaints or whistleblowing concerns, to ensure acceptable conduct within the workplace
operate and keep a record of employee performance and related processes e.g. development and learning, for 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 we comply with duties in relation to individuals with disabilities, meet our 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 the council 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; and maintain and promote equality in the workplace

Where the council relies on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

Where there are special categories of personal data for example:

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)
information about trade union membership is processed to allow the council to operate check-off for union subscriptions
information about ethnic origin, sexual orientation, health or religion or belief, is processed for the purposes of statutory reporting on equalities and diversity monitoring and the council’s workforce analysis

Who your information may be shared with (internally and externally)

Your information may be shared internally with members of the People, Equalities & OD department, your line manager, managers in the business area in which you work, Policy & Insight Team and D&ICT staff if access to the data is necessary for performance of their roles.

The council shares your data with third parties in order to obtain pre-employment references from other employers, obtain employment background checks from third-party providers and obtain necessary criminal records checks from the Disclosure and Barring Service.

The council may also share your information with third parties in order to comply with requests for statutory staffing returns, such as Transparency requirements under the Localism Act, Gender Pay Gap, Publication of Trade Union Facility Time, data required by the Office of National Statistics.

The council may also share your data with third parties in the context of a transfer of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.

The council also shares your data with third parties, such as the council’s HR Business Services provider, our Pensions Administrator, and Occupational Health providers, in matters related to payroll, HR systems management, and the provision of benefits, pension and occupational health services.

There will be times when we are under a legal duty to share information. This includes, but is not limited to:

disclosure under a court order
sharing with the Ministry of Justice for inspection purposes
sharing with the police for the prevention or detection of crime
where there is an overriding public interest to prevent abuse or serious harm to others
disclosure to a Regulator if we identify a situation of potential misconduct or if the information is requested.

We will strive to ensure that any personal data in our care will be kept safe and that where your information is disclosed to a third party working on our behalf, we will seek to ensure that they have sufficient systems and procedures in place to prevent the loss or damage of personal data.

How long we keep your information

We 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 Retention Schedule December 2023 - HRandOD.xlsx

We will then dispose your information in the most secure manner possible.

Transfers to third countries

All the information you provide us is held within the UK & European Economic Area.

Data Matching and Auditing

We are required by law to protect the public funds we administer. We may use the information you provide to us for the prevention and detection of crime. We may also share this information with other bodies that are responsible for auditing or administering public funds including the Department for Work and Pensions, other local authorities, HM Revenue and Customers and the Police.

The council uses data matching as a way of processing large volumes of information. While this can be a useful way of detecting fraud, it also enables us to identify information that is inaccurate or out of date, helping us comply with Data Protection law, while improving service provision.

As part of the council’s fraud prevention and detection activities, the council participates in the National Fraud Initiative (NFI). The data matching exercise is run by the Cabinet Office. More information about this.

Your data protection rights

As a data subject, you have a number of rights. You can:

access and obtain a copy of your data on request;
require the council to change incorrect or incomplete data;
require the council 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 the council is relying on its legitimate interests as the legal ground for processing; and
ask the council to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the council's legitimate grounds for processing data.

The rights available to you depend on our reason for processing your information. For further information about your data protection rights and how to make a request, please see ‘Your rights’

Your right to make a complaint

The Council tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.

If you want to make a complaint you can contact us on:

Complaints Team
London Borough of Hounslow
Hounslow House,
7 Bath Road,
TW3 3EB

Data Protection Officer

The Council’s Data Protection Officer can be contacted on:

InformationGovernance@hounslow.gov.uk

Information Governance Team
London Borough of Hounslow
Hounslow House,
7 Bath Road,
TW3 3EB

Information Commissioner’s Office

The Information Commissioner is the UK's independent body set up to uphold information rights.

If you would like to know more about your rights under the Data Protection law, and what you should expect, visit the Information Commissioner’s website: https://ico.org.uk/

If you have any concerns regarding any privacy practices or about exercising your Data Protection rights, you may contact the Information Commissioner’s Office:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow Cheshire
SK9 5AF

Telephone: 0303 123 1113 or 01625 545 745

Email: casework@ico.org.uk

A full list of what information we control and process and for what purposes is set out in our notification with the Information Commissioner's Register of Data Controllers. Our registration number is Z5761176. You can view our registration on the Information Commissioner's website.