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What we need to collect We need to collect and use (process) personal data about our current and former employees and pensioners to allow us to provide employment support, pension services and to fulfil our contractual requirements and to comply with any mandatory legal obligations arising from employment and social welfare legislation. For data to be considered ‘personal’ it must relate to an identified or identifiable individual. An individual can be identifiable either directly or indirectly. What specific data is used is important, especially as not all data is of equal significance. The more unique a piece of data relates to an individual, the easier it is to identify that individual. An individual is directly identifiable when using common identifiers such as a name, an address, or an assigned email address. Directly identifiable data now includes digital information, such as online identifiers or an IP address which can be related to an individual. An individual can be indirectly identifiable due to association with unique or uncommon personal data, an example is a unique job title within a workplace. If there is only one individual with a specific job title, that individual is indirectly identifiable by that job title. Where we use data that is insufficient to identify an individual this is not considered use of personal data within UK law. If identifiable data is used but the use does not specifically relate to an individual, then this processing is also not considered as making use of personal data. For example, a work email that refers to a work activity, despite the use of an employee’s name within the email’s footer (identifiable data) because the email is related to work the use of the identifiable data is not personal as it does not relate to the sender or receiver of the email but relates to the work activity. As an applicant, employee and subsequently as a former staff pensioner, we will process personal data in order to set up and maintain a contract of employment while also meeting our legal obligations and pursuing our legitimate interests as your employer e.g. your performance management while you are employed by us. This also includes administering the payment of pensions under the St Dunstan’s Retirement Benefits Plan (1973). The minimum personal data necessary will include: Name. Contact Details (Postal address, telephone/mobile number, email address). An employee’s next of Kin contact details in case of emergency. Date of Birth. Gender (as recorded at birth for UK taxation purposes). Your national insurance number. Driving licence and or passport details (where necessary valid visa documentation for work entitlement purposes). Bank account details, salary, tax, pension status, pension entitlement and incurred expenses details. Learning, development and performance details. Your image, when capatured on a CCTV system, Photographs and biographic details (where necessary) e.g. for an staff ID card. Profession and job title. Confidential references. If as an applicant or employee a role will include care duties/functions and or other direct engagement with our beneficiary members it will be necessary for us to complete a Criminal Records Check (Disclosure and Baring Service or Disclosure Scotland) to assist us with the making of safer employee recruitment decisions. The processing of this criminal records data for this purpose is permissible under part 3 of Schedule 1 of DPA 2018. In addition to the above personal data the following may also be processed. DBS / DS Reference number, type of disclosure, date of issue (see section 6). Place of birth. Nationality. Evidence of an employee’s nationality and identity will need to be validated by inspection of a range of your personal documents, examples include, driving licence, marriage or civil partnership certificate, a passport and official letters (as evidence of address). Copies of these documents for this processing purpose will not be retained. We will be very clear when we wish to collect such personal data, we will provide our reason for collecting it and we will only do so when we have a lawful basis for processing the personal data we seek to collect. Special Category data. UK data protection law and regulation recognises certain personal data as ‘special category’ data as being particularly sensitive. This includes; racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, certain biometric data, data concerning health or a person's sex life or sexual orientation. Sometimes we may need to collect or may indirectly obtain such data. For example: Health details (e.g. pre-existing health conditions, occupational health or ill health early retirement), where we need to make reasonable adjustments for your safe and productive employment or appropriate pension payments. Race or ethnic origin, for the purpose of, for example, equal opportunities monitoring or when confirming eligibility to work in the UK. You may reveal some of this personal or special category data if, you share photos, or contribute to our Review magazine, use our website or social media channels. If you freely provide, either at our request or voluntarily, any ‘special category’ sensitive personal data necessary for the employment (or volunteering relationship), you explicitly agree that we may collect and use it for this specific purpose and in accordance with this Privacy Policy. Criminal Offence data. If an applicant’s or employee’s role will include face to face engagement with a Blind Veterans UK Group beneficiary, it is a legal requirement for us to complete a higher-level check known as an enhanced DBS Criminal Records Check from the Disclosure and Baring Service or Disclosure Scotland to assist us with the making of safer employee recruitment decisions. This is in addition to the above personal data. The processing of this criminal offence data for this purpose is permissible under DPA 2018, Schedule 1, Part 3 (See: Section 6 for more details). The accuracy of personal data we hold is really important to us. If it is necessary to make an update or correction to any personal data we hold, some of this can be completed by an individual on a self-service basis using CoreHR. If the personal data needing to be updated or corrected is not held on this platform or is behind behind an access permission restriction please contact your Line Manager, an HR representative or the Payroll and Pension administration office using the contact details in Section 9 of this policy. Data collected and processed on behalf of a controller Blind Veterans UK if contracted to do so will provide business support services to other charities within the Blind Veterans UK Group. When providing these services, such as HR, Finance and IT support, Blind Veterans UK will be operating as a data processor. The requesting Group charity will be the controller and will retain full determination of the purposes of any processing activity. Blind Veterans UK will be processing personal data acting only on the instructions of and on behalf of the controller. Blind Veterans UK has an agreement to provide such services for BRAVO VICTOR. Blind Veterans UK will comply with all UK legal requirements (UK-GDPR, Articles 5 & 28) necessary when acting as a data processor on behalf of BRAVO VICTOR. We will ensure that personal data processed is protected at the same level of assurance applied to all data processed by Blind Veterans UK. Why we need it We need an individual’s personal data in order to perform functions such as: To comply with the law. To comply with the law as a data controller and employer there are data processing purposes which must be completed. These include but are not limited to company, charity, employment, social security, social welfare and data protection law. E.g Confirming an individual's eligibility to work in the UK. Personal data collected specifically for these specific purposes cannot be further processed for a secondary purpose without additional consultation. To manage a contract of employment. As part of the recruitment process and to confirm necessary security vetting, references and to administer other pre-contractual requirements. To administer working hours, holidays and absences, pay, pension and tax. To administer benefits under the St Dunstan’s Retirement Benefits Plan (1973) if enrolled. Provide performance review, learning and development. To develop employee’s skills and knowledge within a chosen profession and career path. To manage job performance and to promote and improve employee effectiveness. Communicate with applicants and employee’s. To maintain two-way communications with applicants and employees about recruitment, employment and pension matters in an appropriate way and to provide specific services, updates, newsletters, feedback and information. To assist with technical problems related to our services. To improve our services and administration. To ensure the most efficient and appropriate use of the resources we have. e collect personal data in a variety of ways. We collect personal data you provide directly to us as well as data we collect indirectly available from other sources, such as an employment referee or from Government departments such as HMRC. Directly from Individuals Individuals will give us personal data directly during the recruitment process and subsequently when establishing and enabling a contract of employment, should an offer be made. Personal data will also be collected directly to manage mandatory and charity development and training requirements of new and continuing employees. Additionally, if an applicant or employee were to use our websites or our mobile apps, sign up for an event, make a donation, purchase merchandise from our on-line shop or instigate communication with us personal data will be collected directly to manage these purposes. Indirectly from other sources We may obtain personal data indirectly when an individual gives consent to other third parties to share it, we can also collect personal data indirectly when it is publicly available: Third party organisations or individuals. We may obtain data from third parties if an individual has agreed they can share personal data with us or we can approach them to ask for it. For example a recruitment agency, a referee, a professional body, a qualification organisation or the Disclosure and Barring Service. We will also obtain personal data indirectly from official sources as part of our employee on-boarding requirements, examples include HMRC for tax purposes or for paying appropriate pensions such as the (St Dunstan’s Retirement Benefits Plan) or Aviva Digital, Online and Social media. Like many charities, personal data is collected through use of our website and mobile apps, we may also collect details about an individual's browser version, an IP address, what computer operating system is being used. This data will aid us to improve the services we offer. Depending on individual settings or the privacy policies for social media and messaging services like LinkedIn, Facebook or Twitter, individuals may enable organisations to access personal data from those accounts or services. Publicly available sources. Public information may include data from places such as Companies House, the electoral register and information that has been published in articles / newspapers / social media, e.g. LinkedIn for recruitment purposes. Another example is our use of the Post Office’s National Change of Address database, that allows us to keep elements of your personal information up to date. Recruitment Process. The Blind Veterans’ UK Group’s recruitment process is managed by a third-party provider (Webrecruit) accessed by link via interaction with the Blind Veterans UK website. The process is seamless, an applicant may not realise they have been redirected to a third-party site during the process. The Webrecruit portal will be used for vacancies within Blind Veterans UK and BRAVO VICTOR. (See processors list). Blind Veterans UK acts as a data processor on behalf of BRAVO VICTOR for when a processing personal data for their recruitment process. The Webrecruit portal requires an applicant to create a user profile and to sign-in to commence an application. The account is necessary for administrative and security purposes and also allows an individual to complete a recruitment application over a period of time, not requiring an application to be completed in a single session. All personal data collected during the application process is necessary and only the minimum required is be collected. This will include special category data for equalities monitoring and a health declaration, these monitoring documents are required to be completed by law but do not form part of the selection process. These documents will not be seen by the recruitment team responsible for the role. However, if an applicant requests a reasonable adjustment to the application process, details of the changes necessary will need to be shared with the recruitment decision makers to facilitate the required changes. When an application is completed the Blind Veterans’ UK recruitment team is able to securely access and download materials from the Webrecruit site. Note that all upload to and downloads from the portal are end to end encrypted. An applicant has full control to delete an uncompleted application and can close the recruitment account. A completed or submitted application can be withdrawn on request by contacting the Blind Veterans HR dept. (See contact details in Section 9). Copies of un-successful applications are retained for a period of six months. Any data collected as part of a successful application is transferred to CoreHR the charity’s HR and payroll platform as part of the onboarding process.