Employee privacy notice | National World Corporate

Last revised October 2022

1. Who are we?

We are National World Publishing Limited and those of its subsidiaries listed in Appendix 1 at the end of this notice. “We”, “NW”, “us” and “our” throughout this notice refers to National World Publishing Limited or whichever of its relevant subsidiaries you are or have been (or, following a recruitment / appointment process, may be) employed or contracted by.

National World Publishing Limited is a subsidiary of National World plc. It is a private company incorporated in England and Wales under number 11499982 with its registered office at Suite E3, Joseph's Well, Hanover Walk, Leeds LS3 1AB. National World Publishing Limited is the data controller.

2. Background

This notice applies to current and former (and prospective) employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We keep our privacy notice under regular review and may update this notice at any time. This version was last updated on the date given at the top of this privacy notice. Please check this notice regularly to ensure you are familiar with the most current version.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using that information and what your rights are under data protection legislation.

3. Information we collect about you

We collect, store and use the following categories of personal information:

Contact details such as name, addresses, telephone number and email address
Date of birth, gender and marital status
Next of kin and emergency contact information
National Insurance number
Bank account details, payroll records and tax status information
Salary, annual leave, pension and benefits information
Start date and leave dates (if different, the dates of your continuous employment)
Location of employment or workplace
Copy of driving licence
Photographs

Performance information
CCTV footage and other information obtained through electronic means such as swipe card records
Recruitment information
Employment records
Compensation history
Disciplinary and grievance information
Information about your use of our information and communications systems
Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied
Accident book records

We may also collect, store and use the following more sensitive types of personal information (special category data):

Race or ethnicity
Religious beliefs
Sexual orientation
Trade union membership
Health data (including medical conditions and sickness records)

We may collect criminal convictions and record information. We will only do so where it is legally permissible and appropriate to do so as part of our recruitment process.

4. How is your personal information collected?

We collect personal information through the recruitment process, either directly from you or from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.

We will collect additional personal information in the course of job-related activities throughout the period you work for us.

5. How we will use information about you

Most commonly, we will use your personal information in the following circumstances:

To perform the employment contract we have entered into with you
To make a decision about your recruitment/appointment
To pay your salary and make any necessary deductions
To provide employment-related benefits
To provide information to our pension provider
To carry out performance reviews, manage performance and set goals
To assist you in the planning of your education, training and development
To monitor equal opportunities and diversity
To monitor your use of our information and communication systems and ensure compliance with our IT policies
To comply with health and safety regulations

Gather evidence for grievance or disciplinary matters
Make decisions about your continued employment/engagement
Deal with legal disputes involving you and/or other employees/contractors
Manage sickness and absence (including making decisions about your fitness for work)
Fraud prevention
Assessing salary reviews and compensation
Business management and planning
Where we need to protect your interests (or someone else's interests)
Where it is needed in the public interest
To assess our employee retention rates

- Pay trade union premiums, register the status of a protected employee and to comply with employment law obligations
- Administer our pension scheme
- Prevent or detect unlawful acts
- Protect you/your interests or those of another person
- Comply with our legal obligations or carry out employment-related legal rights
- Carry out equal opportunities and diversity monitoring using information you provide voluntarily about your race or national or ethnic origin, religious, philosophical or moral beliefs and sexual orientation. This may involve further processing of previously provided information such as gender or working pattern, for example.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.

Change of purpose

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We will not tell you if the purpose is compatible with the original purpose.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. The legal basis for processing your personal information

We will only use your personal data where the law allows us to. Typically we will process your data to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. We may also use your personal information where you’ve provided it on a voluntary basis and consent to us processing it in an agreed way.

7. How we use particularly sensitive personal information

We need to have further justification for collecting and / or storing special category personal data. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information:

In limited circumstances, with your explicit written consent.
Where we need to carry out our legal obligations or exercise rights in connection with employment.
Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.
Where it is necessary to protect you or another person from harm.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

We rely on processing conditions in the Data Protection Act 2018 which relate to the processing of special category data for employment, statutory and regulatory purposes.

Do we need your consent?

We do not need your consent to use your personal information to carry out our legal obligations or for another reason set out in this notice. In limited circumstances, we may ask for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with details of the information that we would like and the reason we need it. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

8. Information about criminal convictions

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data. Data held about an individual's criminal convictions will be held only as long as it is required for employment purposes and will not be disclosed to any unauthorised person. We will use information about criminal convictions and offences to:

Comply with our policy on recruitment of ex-offenders; and
Obtain Disclosure and Barring Service checks for particular roles involving work with children

We rely on legitimate interest grounds to process this information. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

Automated Decision Making

We do not envisage that any decisions will be taken about you using automated means. We will notify you via a memo on this website and intranet if this changes.

9. Data sharing

We may share your data with third parties, including third-party service providers and other entities in the group.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

The following activities are carried out by third-party service providers:

pension administration;
benefits provision and administration; and
some IT services

How secure is my information with third-party service providers and other entities in our group?

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.

When might you share my personal information with other entities in the group?

We utilise the same systems and software as other entities in our group. We will share your personal information with other entities in our group as part of our day-to-day business, for regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, and for system maintenance support and hosting of data.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC, disclosures to stock exchange regulators and disclosures to shareholders such as directors' remuneration reporting requirements.We may need to share your personal information to assist law enforcement or comply with legal requirements. This may include in the preparation of tribunal or court cases.

Transferring information outside the UK

We may transfer your personal information outside the UK where our service providers and/or their sub-processors host, process, or store personal information outside the UK. Where this is the case we use contractual arrangements and safeguards to protect this personal information (as required by Article 46 of the UK GDPR), these safeguards include:

The country to which the personal information will be transferred has been deemed to provide an adequate level of protection for personal information by the Information Commissioner's Office (ICO).
Where we use certain service providers, we may use specific contractual clauses set out by the ICO which give personal information the same protection it has in the UK. For further details, see ICO International Data Transfer Agreement and Guidance.

10. Data retention and security

How is my data kept secure?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also have procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it. Details of retention periods for different aspects of your personal information are available in our HR Data Retention Policy.To determine the appropriate retention period for personal data, we consider:

The amount, nature and sensitivity of the personal data.
The potential risk of harm from unauthorised use or disclosure of your personal data.
The purposes for which we process your personal data and whether we can achieve those purposes through other means.
The applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use that information without further notice to you. Once you are no longer an employee, worker or contractor of the company, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

Rights of access, correction, erasure and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Details about your rights can be found on the ICO's website. If you want to exercise any of your rights, please contact our DPO in writing.

11. Questions or complaints

We have appointed a DPO to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact them at [email protected]. You have the right to make a complaint at any time to the ICO which regulates and supervises the use of Personal Data in the UK, via their helpline on 0303 123 1113. We would appreciate the opportunity to address your concern so please contact us in the first instance.

Appendix 1 - List of Relevant National World Subsidiaries

National World Midlands Limited
National World NMSY Limited
National World North East Limited
National World NI Limited
National World North West Limited
National World Off Road Limited
National World Scotsman Publications Limited
National World South Limited
National World SWP Limited
National World Yorkshire Limited