GDPR Privacy Policy


Introduction

Scope of this Workplace Privacy Notice (“Privacy Notice”)

Like most businesses, we hold and process a wide range of information, some of which relates to individuals who work for us.  This Privacy Notice explains the type of information we process, why we are processing it and how that processing may affect you.

This Privacy Notice focuses on individuals who work for us, whether they are employees or freelancers/contractors.  It also covers information on those who apply to work for us, and former employees.

This Privacy Notice comprises this document (the Core Notice) and the Supplementary Information in the Annex to this document.

The Supplementary Information section contains a Glossary, in which we explain what we mean by “personal data”, “processing”, “sensitive personal data” and other terms used in this Privacy Notice.

In brief, this Privacy Notice explains:

  • what personal data we hold and why we process it;
  • the legal grounds that allow us to process your personal data;
  • where the data comes from, who gets to see it and how long we keep it;
  • how to access your personal data and other rights; and
  • how to contact us.

Personal data – what we hold and why we process it

We hold various types of data about the individuals who work for us, including their personal details, information about the work they do for us, their salary and other contractual terms, and so on.  Further examples of the types of data we hold are given in the Supplementary Information.

We process this data for the purposes of our business, including management, administrative, employment and legal purposes.  The Supplementary Information provides more specific information on these purposes.

See Further information on the data we process and our purposes.

Legal grounds for processing personal data

Under data protection law, there are various grounds on which we can rely when processing your personal data.  In some contexts, more than one ground applies.  We have summarised these grounds as Contract, Legal Obligation, Legitimate Interests and Consent, and you can find further information on each in the Supplementary Information.  See Legal grounds for processing personal data.

Where the personal data comes from and who gets to see it

Some of the personal data that we process about you comes from you.  For example, you tell us your contact and banking details.

Other personal data about you is generated in the course of your work, for example, from your managers, colleagues and customers or others outside our organisation with whom you deal.

Your personal data will be seen internally by managers, HR and, in some circumstances, where appropriate, other colleagues.  We may also pass your data outside the organisation, for example to people you are dealing with (e.g clients of third-party suppliers), to our group payroll service, employee benefits insurers and our group qualifying pension provider.

Further information on this is provided in the Supplementary Information.  See “Where the personal data comes from and Who gets to see your personal data?

How long do we keep your personal data?

We do not keep your personal data for any specific period, but we will not keep it for longer than is necessary for our purposes.  In general, we will keep your personal data for the duration of your employment and for a period afterwards in compliance with applicable law.

See Retaining your personal data – more information in the Supplementary Information.

Transfers of personal data outside the EEA

We may transfer your personal data outside the EEA to members of our group and processors in the United States.

Further information on these transfers and the measures taken to safeguard your personal data are set out in the Supplementary Information under Transfers of personal data outside the EEA – more information.

Your personal data rights

You have a right to make a subject access request to receive information about the personal data that we process about you.  Further information on this and on other rights is in the Supplementary Information under Access to your personal data and other rights.  We also explain how to make a complaint about our processing of your data.

Contact details

In processing your personal data, we act as a “data controller”.  Our contact details are as follows:

CPM Field Marketing
47 Aylesbury Road, Thame, Oxon, OX9 3PG
The contact details of the CPM Group Data Compliance & Privacy Officer are as follows:
Christopher McDonnell

christopher.mcdonnell@cpm-int.com

Status of this notice

This Privacy Notice does not form part of your contract of employment and does not create contractual rights or obligations.  It may be amended by us at any time.

Annex To Core Notice

Supplementary information

Glossary

Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system.  It includes not only facts about you, but also intentions and opinions about you.

Personal data “processed automatically” includes information held on, or relating to use of, a computer, laptop, mobile phone or similar device.  It covers data derived from equipment such as access passes within a building, data on use of vehicles and sound and image data such as CCTV or photographs.

Processing” means doing anything with the data.  For example, it includes collecting it, holding it, disclosing it and deleting it.

Sensitive personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data.  These types of data are subject to special protection under the law.

References in the Privacy Notice to “employment”, “work” and similar expressions include any arrangement under which an individual works for us or provides services to us.  This includes individuals who are our employees and also those who provide services under a freelance or independent contractor arrangement.  Similarly, when we mention an “employment contract”, this should be taken to include any contract with an employee, a freelancer or a contractor; and when we refer to ending your “employment”, that includes terminating a freelance engagement or a contract for services.

We use the word “you” to refer to anyone within the scope of this Privacy Notice.

Legal grounds for processing personal data

What are the grounds for processing?

Under data protection law, there are various grounds on which we can rely when processing your personal data.  In some contexts, more than one ground applies.  We have summarised these grounds as Contract, Legal obligation, Legitimate Interests and Consent and outline what those terms mean in the following table.

Term Ground for processing Explanation
Contract Processing necessary for performance of a contract with you or to take steps at your request to enter a contract This covers carrying out our contractual duties and exercising our contractual rights.
Legal obligation Processing necessary to comply with our legal obligations Ensuring we perform our legal and regulatory obligations.  For example, providing a safe place of work and avoiding unlawful discrimination
Legitimate Interests Processing necessary for our or a third party’s legitimate interests We (and third parties) have legitimate interests in carrying out, managing and administering our respective businesses. Part of managing a business will involve the processing of your personal data.

Your data will not be processed if, in processing your data, your interests, rights and freedoms related to the data override the business’ interests in processing the data for business purposes.

Consent You have given specific consent to processing your data In general processing of your data in connection with employment is not conditional on your consent.   But there may be occasions where we do specific things such as provide a reference, deduct union dues or obtain medical reports and rely on your consent to do so.

Processing sensitive personal data

If we process sensitive personal data about you, as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one or more of the grounds for processing sensitive personal data applies.  In outline, these include:

  • Processing being necessary for the purposes of your or our obligations and rights in relation to employment in so far as it is authorised by law or collective agreement (e.g. processing health data about you so we can comply with our duties to provide you with a healthy and safe work environment);
  • Processing relating to data about you that you have made public (e.g. if you tell colleagues that you are ill);
  • Processing being necessary for the purpose of establishing, making or defending legal claims (e.g. processing data about your race in relation to defending a race discrimination claim by another employee);
  • Processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity;
  • Processing for equality and diversity purposes to the extent permitted by law.

Further information on the personal data we process and our purposes

The purposes for which we process your personal data, examples of the personal data that may be processed, and the grounds on which we process it, are set out in the table below.

The examples in the table cannot, of course, be exhaustive.  For example, although the table does not mention personal data relating to criminal offences, if we were to find out that someone working for us was suspected of committing a criminal offence, we might process that information if relevant for our purposes.

Purpose Examples of personal data that may be processed Grounds for processing
Recruitment Information concerning your application and our assessment of it, your references, any checks we may make to verify information provided or background checks and any information connected with your right to work in the Spain.  If relevant, we may also process information concerning your health, any disability and in connection with any adjustments to working arrangements. Contract

Legal obligation

Legitimate interests

Your employment contract including entering into it, performing it and changing it. Information on your terms of employment from time to time including your pay and benefits, such as your participation in pension arrangements, life and medical insurance; and any bonus or share schemes. Contract

Legal obligation

Legitimate interests

Contacting you or others on your behalf Your address and phone number, emergency contact information and information on your next of kin Contract

Legitimate interests

Payroll administration and other financial benefits (including life assurance) Information on your bank account, pension contributions and on tax and national insurance

Information on attendance, holiday and other leave and sickness absence

Contract

Legal obligation

Legitimate interests

Supporting and managing your work and performance and any health concerns Information connected with your work, anything you do at work and your performance including records of documents and emails created by or relating to you and information on your use of our systems including computers, laptops or other device.

Management information regarding you including notes of meetings and appraisal records.

Information relating to your compliance with our policies.

Information concerning disciplinary allegations, investigations and processes and relating to grievances in which you are or may be directly or indirectly involved.

Information concerning your health, including self-certification forms, fit notes and medical and occupational health reports.

Contract

Legal obligation

Legitimate interests

Changing or ending your working arrangements Information connected with anything that may affect your continuing employment or the terms on which you work including any proposal to promote you, to change your pay or benefits, to change your working arrangements or to end your employment. Contract

Legitimate interests

Physical and system security CCTV images.

Records of use of swipe and similar entry cards.

Records of your use of our systems including computers, phones and other devices and passwords.

Legal obligation

Legitimate interests

Providing references in connection with your finding new employment Information on your work for us and on your performance. Consent

Legitimate interests

Providing information to third parties in connection with transactions that we contemplate or carry out Information on your contract and other employment data that may be required by a party to a transaction such as a prospective purchaser, seller or outsourcer. Legitimate interests
Monitoring of diversity and equal opportunities Information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age. Legitimate interests
Monitoring and investigating compliance with policies and rules – both generally and specifically We expect our employees to comply with our policies and rules and may monitor our systems to check compliance (e.g. rules on accessing pornography at work).  We may also have specific concerns about compliance and check system and other data to look into those concerns (e.g. log in records, records of usage and emails and documents, CCTV images). Legitimate interests
Disputes and legal proceedings Any information relevant or potentially relevant to a dispute or legal proceeding affecting us. Legitimate interests

Legal obligation

Day to day business operations including marketing and client relations Information relating to the work you do for us, your role and contact details including relations with current or potential clients.   This may include a picture of you for internal or external use or where we use a contact app such as Names & Faces. Legitimate interests
Maintaining appropriate business records during and after your employment Information relating to your work, anything you do at work and your performance relevant to such records. Contract

Legal obligation

Legitimate interests

Operation of active directory/authentication Information on your name, job title, managers, contact details, and other information from time to time. Legitimate interests
IT technical support, back up and disaster recovery Any information required to notify you of and/or to resolve the technical difficulty experienced. Legitimate interests
Back office services, including staff passes, mailroom, catering, cashless vending, and reception Information including your name, job title, work location, contact details, and other information from time to time. Legitimate interests

 

Where the personal data comes from

  1. When you start employment with us, the initial personal data about you that we process is likely to come from you: for example, contact details, bank details and information on your immigration status and whether you can lawfully work.  We may also require references and information to carry out background checks.
  2. In the course of employment, you may be required to provide us with information for other purposes such as sick pay (and SSP) and family rights (e.g. maternity and paternity leave and pay). If you do not provide information that you are required by statute or contract to give us, you may lose benefits, or we may decide not to employ you or to end your contract.  If you have concerns about this in a particular context, you should speak to HR.
  3. In the course of your work, we may receive personal data relating to you from others. Internally, personal data may be derived from your managers and other colleagues or our IT systems; externally, it may be derived from our clients or those with whom you communicate by email or other systems.

 

Who gets to see your personal data?

Internal use

Your personal data may be disclosed to your managers, HR and administrators for employment, administrative and management purposes as mentioned in this document.  We may also disclose this to other members of our group and to Omnicom for the same purposes.

External use

We will only disclose your personal data outside our group if disclosure is consistent with one or more of our legal grounds for processing and if doing so is lawful and fair to you.

We may disclose your personal data if it is necessary for our legitimate interests as an organisation or the interests of a third party, such as when we provide you employment benefits we may need to use a third party to provide these which will involve disclosing your personal data to them (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy).

We may also disclose your personal data outside the group:

  1. if you consent to the disclosure;
  2. where we are required to do so by law; or
  • in connection with criminal or regulatory investigations.

Specific circumstances in which your personal data may be disclosed include:

  • Disclosure to organisations that process data on our behalf such as our payroll service, insurers and other benefit providers, our bank and organisations that host our IT systems and data;
  • Disclosure to external recipients of electronic communications (such as emails) which contain your personal data;
  • Disclosure on a confidential basis to a potential buyer of our business or company for the purposes of evaluation – but only if we were to contemplate selling;
  • Disclosure to Omnicom owned internal shared services groups which administer people-related systems such as HRIS, payroll and benefits administration;
  • Disclosure to parent companies for the purposes of managing the business (e.g. in connection with personal performance review including bonus or career development matters);

Retaining your personal data – more information

Although there is no specific period for which we will keep your personal data, we will not keep it for longer than is necessary for the purposes described in this Privacy Notice.

In general, we will keep your personal data for the duration of your employment and for a period afterwards, in compliance with applicable law.  In considering how long to keep it, we will take into account its relevance to our business and your employment.

If your personal data is only useful for a short period (for example, CCTV footage or a record of a holiday request), we may delete it.

Personal data relating to job applicants (other than the person who is successful) will be deleted in compliance with applicable law.

Transfers of personal data outside the EEA – more information

In connection with our business and for employment, administrative, management and legal purposes, we may transfer your personal data outside the EEA to members of our group and processors in the United States. We will ensure that the transfer is lawful and that there are appropriate security arrangements.

Although there is no decision by the European Commission that the United States provides an adequate level of protection, we are drafting and will enter into an agreement ensuring appropriate and suitable safeguards with our group members in and processors in the United States.  These will be on standard terms adopted by the Information Commissioner and approved by the Commission.

Access to your personal data and other rights

We try to be as open as we reasonably can about personal data that we process.  If you would like specific information about your data, just ask us.

You also have a legal right to make a “subject access request”.  If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including:

  • Giving you a description and copy of the personal data; and
  • Telling you why we are processing it.

If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.

As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted.  If you have provided us with data about yourself (for example your address or bank details), and the ground for processing is Consent or Contract, you have the right to be given the personal data in machine readable format for transmitting to another data controller.

If we have relied on consent as a ground for processing, you may withdraw consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.

If you choose to exercise your right to make a “subject access request”, we encourage you to do so by completing a webform at the following link: https://privacyportal-eu.onetrust.com/webform/12e0cd13-1eac-4cbd-8fbd-8e3ed7bc5769/b173013c-2df0-4ab8-b31e-5151ffe27a1a

Complaints

If you have complaints relating to our processing of your personal data, you should raise these with HR in the first instance. You may also raise complaints with the Information Commissioner who is the statutory regulator.  For contact and other details ask HR or see:  https://ico.org.uk/

 

 

Register for job alerts


Register/Login

Never miss out on that perfect opportunity. Register your details with us and we’ll let you know when we have an opening – or openings – that could be just what you’re looking for.

Register/Login