This policy defines the some of the core requirements for privacy and how we process data and is applicable to all JMTechnical Group contracts. The policy is applicable to current and former JMTechnical Group employees and contractors.

Data Protection Principles

We will comply with the data protection principles under the data protection legislation. This says that the personal information we hold about you must be:

- used lawfully, fairly and in a transparent way
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- relevant to the purposes we have told you about and limited only to those purposes
- accurate and kept up to date
- kept only as long as necessary for the purposes we have told you about
- kept securely

Type of Information Held

- Personal data, or personal information refers to any information about individuals from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
- CCTV footage and other information obtained through electronic means such as swipe card records
- Records about use of our information and communications systems
- Sounds or visual images (for example, photographs, videos)
- Goods or service s provided

Privacy Policy Guidelines

We typically collect personal information about employees and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We will sometimes collect additional information from third parties including former employers, credit reference agencies or other agencies.

Our legal basis for processing your personal data

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

- for official purposes
- where it is necessary for the purposes of the legitimate interests pursued by a third party
- where we need to comply with a legal obligation
- where it is necessary for performing a contract
- where we have your informed consent
- there can be rare occasions where it becomes necessary to use your personal information to protect your interests (or someone else’s interests)

Why are we collecting or processing data

We need all the categories of information to enable us to perform an employment requirement or to enable us to comply with other legal obligations. The situations in which we will process your personal information are listed below:

- making decisions about your recruitment or appointment
- determining the terms on which you work for us
- checking you are legally entitled to work in the UK and to provide you with the security clearance appropriate for your role
- paying you
- providing employment-related benefits to you
- general administration of any contract we have entered into with you
- business management and planning, including accounting and auditing, conducting performance reviews, managing performance and determining performance requirements
making decisions about salary reviews and compensation
- assessing qualifications for a particular job or task, including decisions about promotions
- gathering evidence and any other steps relating to possible grievance or disciplinary matters and associated hearings
- making decisions about your continued employment or engagement
- making arrangements for the termination of our working relationship education, training and development requirements
- dealing with legal disputes involving you, or
- ascertaining your fitness to work, managing sickness absence
- complying with health and safety obligations
- to prevent fraud
- to monitor your business and personal use of our information and communication systems to ensure compliance with our IT policies
- to ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
- to provide and administer security and intelligence matters
- to carry out policing, including the prevention and detection of crime (including CCTV); apprehension and prosecution of offenders, protection of life and property; maintenance of law and order
- to conduct data analytics studies to review and better understand retention and equal opportunities monitoring
- dealing with Freedom of Information Act/Environmental Information Regulations requests

Some of the purposes will overlap and there can be several grounds which justify our use of your personal information.

Failure to Provide Information

If you fail to provide certain information when requested, we will not be able to fully perform our legal, security and employment obligations, or we could be prevented from complying with our legal obligations, such as to ensure the health and safety of our workers.

How We Store Personal Data

Your personal data will be stored in a secure JMTechnical Group information management systems. 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.

In addition, we limit access to your personal information to only management and other third parties who have a business need to know. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure, in a contractual arrangement.

We have put in place procedures to deal with any suspected data security breach and will notify you and of a suspected breach where we are legally required to do so.

Sharing Your Personal Data

We will in some circumstances have to share your data with third parties, including third-party stakeholders. We require third parties to respect the security of your data and to treat it in accordance with the law.

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 it is necessary for the fulfilment of our contracts. We do not allow our third-party stakeholders 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.

Data Retention Period

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

After the retention period, has elapsed all data will be destroyed securely in line with JMTechnical Group policy and/or applicable legislation.

In some circumstances, we will anonymise your personal information so that it can no longer be associated with you, in which case we will use such information without further notice to you.

Duty To Inform

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

Request access to your personal information

This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. If you want to find out if JMTechnical Group holds any personal information about you, or want to make any corrections, you can make a ‘subject access request’ (SAR) under the Data Protection legislation. If we do hold information about you, we will:

- give you a description of it
- tell you why we are holding it
- tell you to whom it has, or will be disclosed, in particular if it has been disclosed to international organisations
- let you have a copy of the information in a form that is as clear and understandable as possible

There are a small number of cases where we do not have to give you the information you have asked for. For example, if we are using data for the purposes of investigating, preventing or detecting crime, or apprehending or prosecuting offenders where to do so would be likely to prejudice those purposes. In cases where it is known the police are investigating, or prosecuting offences, we will ask for their view on whether providing you with the information would prejudice their activities.

Request data correction - This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request data erasure - This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
Object to processing your data - Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information - This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Right to withdraw consent - In the limited circumstances where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

This document was last reviewed and updated on 22 April 2023.