Employee and worker

To support your employment or engagement with Link, we collect and maintain a range of personal information that reflects your role, responsibilities and working arrangements. 

This includes: 

• Personal and contact details – such as your name, address, contact details, date of birth, and gender.
• Employment and recruitment information – including roles applied for, employment history, qualifications, professional memberships, references, and terms and conditions of employment or engagement
• Pay and benefits information – including salary, allowances, pension and benefits information, bank account details, National Insurance number and employee reference numbers
• Working arrangements and attendance – including working hours, work patterns, location, attendance records and details of leave such as sickness absence, annual leave and family leave
• Performance and employment records – including appraisals, performance and probationary reviews, training and development activity, and records relating to disciplinary, grievance, dignity at work or capability processes
• Health and wellbeing information – where relevant, including medical information, disability status, occupational health reports and information required to support reasonable adjustments
• Compliance and safeguarding information – including right to work information, and where required for the role, criminal conviction details, PVG membership, and professional or regulatory registration details
• Other supporting information – including emergency and close contact details, photograph, trade union membership where applicable, and equality monitoring information which is voluntary 

In some roles, additional information may be processed where this is necessary for operational, safety or compliance reasons. This may include: 

• information obtained through CCTV systems or access controls
• call recordings where telephony systems are used
• IT system usage and access data
• monitoring software for billing hours to third party clients
• vehicle or location data where company vehicles are used
• Office signing in and out times, dates and location
• location data where a lone worker alarm is activated 

The level and type of information collected will depend on your role and the nature of your work with Link. Where monitoring activities are carried out, this is undertaken to support legitimate organisational needs such as ensuring the safety of systems, and premises, protecting staff safety, preventing and detecting misconduct, and ensuring the effective service of operations. 

Monitoring is carried out in a proportionate and transparent way, and only when necessary for the defined purpose.

Personal information is used to manage working relationships, support service delivery and ensure Link meets its obligations as an employer and service provider.

This includes: 

• administering pay, pensions and employee benefits
• managing contracts and maintaining accurate employment and engagement records
• supporting recruitment, onboarding and workforce planning
• managing performance, learning and development, and career progression
• managing attendance, leave and absence arrangements
• supporting health, safety and wellbeing, including obtaining medical advice where required
• ensuring appropriate safeguarding arrangements and compliance with regulatory requirements
• maintaining appropriate standards of conduct and resolving workplace issues such as disciplinary or grievance matters
• responding to incidents, complaints, regulator requests or legal claims 

Information from operational systems may also be used where relevant to support the effective delivery of services. For example, information such as vehicle location data or lone working arrangements may be used to support staff safety, coordinate services, manage resources or investigate incidents where appropriate. 

Equality monitoring information may be used by Link on an aggregated and anonymised basis to understand workforce trends and support the development of policies, training and communications. This information is considered at a high level only and is not used to make decisions about identifiable individuals. 

Without this, Link may not be able to meet contractual or legal obligations, including paying you or ensuring you can safely and lawfully carry out your role.

Your information is held securely within Link’s internal service delivery, and document management systems. Relevant information may also be provided to authorised third parties supporting services such as pensions, benefits, occupational health, performance and development system providers and training.

Access to information is controlled based on role and business need, and systems are configured to ensure appropriate security, audit and access controls are in place. Link applies appropriate technical and organisational measures to protect personal data from loss, misuse, unauthorised access or disclosure.

Personal information is retained for as long as necessary to manage your employment or engagement and to meet legal, regulatory and operational requirements. 

Retention periods are set out in Link’s data retention schedule, which can be accessed here, and are reviewed on a regular basis. Where information is no longer required, it will be securely deleted or anonymised.

Link processes personal information in line with UK data protection legislation. The legal bases relied on will depend on the purpose of processing and the type of information involved. 

These include: 

• Contractual obligations – to enter into and manage employment or engagement relationships, including payment and provision of benefits
• Legal obligations – to comply with statutory and regulatory requirements, such as tax, employment law, safeguarding duties and right to work checks
• Legitimate interests – to support the effective operation of Link, including workforce management, service delivery, business administration and organisational security
• Consent – where required for specific purposes, such as certain types of optional data or communications, which you can withdraw at any time. 

In addition, some information processed by Link falls within special category data under data protection law. This includes information such as health data, disability information and equality monitoring data. This data is processed where necessary for the purposes of carrying out obligations and exercising specific rights in employment law, to support health and safety obligations or for reasons of substantial public interest (equality of opportunity and treatment), where there is a clear basis in law. Appropriate safeguards are in place to ensure this data is handled securely and only accessed where necessary.   

Where relevant for a role, Link may also process criminal conviction data for Disclosure Scotland checks and/or PVG scheme membership). This data is processed only where it is necessary in line with employment and safeguarding requirements and where there is a clear basis under data protection legislation. Link maintains an appropriate policy document which sets out how this information is managed, retained and protected in line with statutory requirements.

Personal information is shared where this is necessary to support employment, service delivery and compliance with legal or regulatory requirements. 

Within Link, where there is a legitimate requirement to do so, information may be shared within HR and L&D, Corporate Services teams, line managers, and wider management teams. Outside Link, information may be shared with: 

• payroll, pension and benefits providers
• occupational health and training providers
• regulatory bodies and government agencies (for example HMRC, Disclosure Scotland or relevant professional bodies)
• auditors, insurers and legal advisers

In some cases, information may also be shared in connection with external requirements such as audits, accreditations, TUPE transfers, or legal proceedings. 

Organisations receiving information will either do so on behalf of Link or as part of their own statutory or regulatory responsibilities. In all cases, appropriate safeguards are in place and only the minimum necessary information is shared.

Most of the information held by Link is provided directly by you during recruitment and throughout your employment or engagement. 

Information may also be obtained from other sources where relevant, including:

• recruitment agencies, referees or previous employers
• background checking providers and regulatory bodies (such as Disclosure Scotland or professional regulators)
• occupational health providers or medical advisers
• training providers or accreditation bodies
• internal systems, including IT systems, access controls, telephony systems or vehicle systems
• publicly available sources, such as professional registers or publicly accessible personal and professional information where this is relevant and lawfully obtained

If your details change, please update these in iTrent ESS, or if it is not captured there, please contact 03451 400 100 to inform us to ensure that all of the information we hold about you is up to date.

You can also contact our data protection officer at  datamanagement@linkhaltd.co.uk  or by post to Link House, 2c New Mart Road, Edinburgh EH14 14L.

You have the right to ask us for copies of your personal information. 

You have the right to ask us to erase your personal information in certain circumstances. 

You have the right to restrict the processing of your personal information in certain circumstances.

You have the  right to object to the processing of your personal information in certain circumstances . However, if Link can demonstrate that there is a compelling reason to process such personal data then we may refuse to stop processing your personal data.  

You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.