Privacy Policy

01WHAT IS THE PURPOSE OF THIS DOCUMENT?

1.1 Key points

1. Oasis Accountants is committed to protecting the privacy and security of your personal information.
2. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the UK General Data Protection Regulation.
3. It applies to all employees, workers and freelance contractors, and in part to interns and volunteers.

1.2 In more detail

1. Oasis Accountants is a “controller” (also called a “data controller”). This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
2. This notice applies to current and former employees, workers and freelance contractors. It will also apply to interns and volunteers, to the extent that data of the types described in this notice is actually processed by Oasis Accountants in relation to such individuals.
3. This notice does not form part of any contract of employment or other contract between us. We may update this notice at any time, but if we do so, we will provide you with an updated copy as soon as reasonably practicable.
4. 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 such information and what your rights are under the data protection legislation.

02Data protection principles

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

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

03The kind of information we hold about you

Categories of personal information we may collect

1. Personal contact details such as name, title, addresses, telephone numbers and personal email addresses.
2. Date of birth.
3. Gender.
4. Marital status and dependents.
5. Next of kin and emergency contact information.
6. National Insurance number.
7. Bank account details, payroll records and tax status information.
8. Salary, annual leave, pension and benefits information.
9. Start date and, if different, the date of your continuous employment/engagement.
10. Leaving date and your reason for leaving.
11. Location of employment or workplace.
12. Copy of driving licence.
13. Recruitment information (including right-to-work documentation, references and CV/cover letter information).
14. Employment records (including job titles, work history, working hours, training records and professional memberships).
15. Compensation history.
16. Performance information.
17. Disciplinary and grievance information.
18. CCTV footage and other information obtained through electronic means such as swipe card records.
19. Telephone calls, emails or other communications with you.
20. Information about your use of our information and communications systems.
21. Photographs.
22. Passport, visa, right-to-work documents and/or sponsorship papers.
23. Results of HMRC employment status check, details of your interest in and connection with any intermediary through which your services are supplied.

Special categories of more sensitive personal information

1. Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
2. Trade union membership.
3. Information about your health, including any medical condition, health and sickness records, including:
   1. where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision;
   2. details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and
   3. where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.
4. Genetic information and biometric data.
5. Information about criminal convictions and offences.

04How is your personal information collected?

We collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency/business or Accountants company, from online sources (such as LinkedIn), from CV databases, or from a background check provider. We may sometimes collect additional information from third parties including former employers/engagers, referees, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies or other background check agencies.

We may also collect personal information from the trustees or managers of pension arrangements operated by a group company.

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

05Sending us personal information and documents

Please note that we cannot guarantee email to be a secure way to send personal information, such as copies of passport, driving licence or other personal documents.

For this reason, we provide a secure portal on our website, accessible only by username and password, where you can upload documents containing personal information.

If you nevertheless choose to send such documents by email, this will be your own choice, and at your own risk.

06How we will use information about you

6.2 Situations in which we will use your personal information

1. Making a decision about your recruitment, appointment or engagement.
2. Seeking, placing you in, and managing your assignments.
3. Determining the terms on which you work for us.
4. Checking you are legally entitled to work in the UK.
5. Paying you and, where applicable, deducting tax and National Insurance contributions.
6. Providing benefits to you, including share plans operated by a group company (invitation, granting awards, administration, and collecting any tax/NICs due).
7. Enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties.
8. Liaising with the trustees or managers of pension arrangements, your pension provider and any other benefits provider.
9. Administering the contract we have entered into with you.
10. Business operation, management, and planning, including accounting and auditing.
11. Conducting performance reviews and determining performance requirements.
12. Making decisions about salary reviews and compensation.
13. Assessing qualifications for a particular job or task, including decisions about promotions.
14. Gathering evidence for possible grievance or disciplinary hearings.
15. Making decisions about your continued employment or engagement.
16. Making arrangements for the termination of our working relationship.
17. Education, training and development requirements.
18. Checking any instruction or information given to us.
19. Improving the quality of our service.
20. Dealing with legal disputes and insurance claims, including accidents at work.
21. Ascertaining your fitness to work.
22. Managing sickness absence.
23. Complying with health and safety obligations.
24. Preventing fraud or other criminal activity.
25. Monitoring your use of our IT and communications systems for compliance with our IT policies.
26. Ensuring network and information security.
27. Conducting data analytics studies to review employee retention and attrition rates.
28. Demonstrating our own compliance with legal obligations to third parties with legitimate interests in our compliance.
29. Managing and maintaining any applicable insurance policies.
30. Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

6.3 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 (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations.

6.4 Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use it for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. We may process your personal information without your knowledge or consent where this is required or permitted by law.

07How we use particularly sensitive personal information

7.2 Our obligations

1. We may use information about leaves of absence, including sickness or family-related leaves, to comply with employment and other laws.
2. We may use information about your physical or mental health, or disability status, to ensure your health and safety, assess fitness to work, provide workplace adjustments, manage sickness absence, and administer benefits including statutory maternity pay, statutory sick pay, pensions and permanent health insurance.
3. If you leave employment and under any share plan operated by a group company the reason for leaving is ill-health, injury or disability, we will use information about your health in reaching a decision about your entitlements.
4. If you apply for an ill-health pension under a pension arrangement operated by a group company, we will use information about your physical or mental health in reaching a decision.
5. We may use information about race, ethnic origin, religious beliefs, sexual life or sexual orientation for meaningful equal opportunity monitoring and reporting.
6. We may use trade union membership information to pay trade union premiums, register the status of a protected employee and comply with employment law obligations.

7.3 Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent. If we do so, we will provide full details so you can carefully consider whether to consent. It is not a condition of your contract that you agree to any request for consent from us.

08Information about criminal convictions

We envisage that we may hold information about criminal convictions. We will only collect such information if appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect this information as part of the recruitment process, or we may be notified by you in the course of your working for us. We will use this information to:

1. Ensure you are suitable for assignments for which you are considered.
2. LIST

We are allowed to use your personal information in this way SPECIFY LAWFUL BASIS. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

09Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

10Data sharing

10.2 Why might we share your personal information with third parties?

1. Where required by law.
2. To seek, place you in, or manage your assignments.
3. Where necessary to administer the working relationship with you.
4. To demonstrate our compliance with legal obligations to third parties with legitimate interests, including any agency or client through/for whom you may be working.
5. To manage and maintain insurance policies.
6. Where we have your informed consent.
7. Where we have another legitimate interest in doing so.

10.3 Which third-party service providers process your personal information?

The following activities may be carried out by third-party service providers: payroll, payslip verification, tax and other compliance checking, pension provision and administration, benefits provision and administration, and IT services.

We may share personal data relating to your participation in any share plans operated by a group company with third-party administrators, nominees, registrars and trustees for the purposes of administering the share plans.

10.4 How secure is your information with third-party providers and group entities?

All third-party service providers and other entities in the group are required to take appropriate security measures in line with our policies. We do not allow third-party service providers to use your personal data for their own purposes — they may only process it for specified purposes and in accordance with our instructions.

10.5 When might we share with other group entities?

We will share your personal information with other entities in our group as part of regular reporting on company performance, in the context of business reorganisation or group restructuring, and for system maintenance and data hosting. We will also share data relating to participation in share plans and pension arrangements operated by a group company with other group entities for administration purposes.

10.6 Other third parties

We may share your personal information with other third parties, for example in the context of a possible sale or restructuring of the business. In this situation, so far as possible, we will share anonymised data before the transaction completes. Once completed, we will share your personal data with the other parties as required under the terms of the transaction.

We may also share information with a regulator or to otherwise comply with the law. This may include making returns to HMRC, Gender Pay Gap reporting, disclosures to stock exchange regulators, and disclosures to shareholders such as directors’ remuneration reporting.

10.7 Transferring information outside the UK

We may transfer the personal information we collect about you to country/countries outside the UK in order to perform our contract with you. There are/are not adequacy regulations in respect of those countries. To ensure your personal information receives an adequate level of protection, we have put in place appropriate measures such as Standard Contractual Clauses. Further information about these protective measures can be requested from the Data Compliance Manager.

With your explicit consent (for example in connection with a specific application for work), we may also transfer personal information we collect about you to other countries outside the UK, regardless of the possible risks due to the absence of an adequacy decision and appropriate safeguards.

11Data security

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 limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details may be obtained from the Data Compliance Manager.

We have put in place procedures 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.

12Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for satisfying any legal, accounting or reporting requirements. Details of retention periods are available in our retention policy from the Data Compliance Manager. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the data and whether we can achieve those purposes through other means, and applicable legal requirements. Where we may be considered an employment business, we are required by law to retain candidates’ personal data for at least one year after we last provided services to them.

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 such information without further notice. Once you are no longer an employee, worker or contractor of the company, we will retain and in due course securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations.

13Rights of access, correction, erasure and restriction

13.1 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.

13.2 Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

1. Request access to your personal information (a “data subject access request”) — a copy of the information we hold and a check that we are lawfully processing it.
2. Request correction of any incomplete or inaccurate information we hold.
3. Request erasure where there is no good reason for us continuing to process it, including where you have exercised your right to object.
4. Object to processing where we are relying on legitimate interest and there is something about your particular situation which makes you want to object, or where we are processing for direct marketing.
5. Request restriction — to suspend processing, for example to establish accuracy or the reason for processing.
6. Request transfer of your personal information to another party.

To exercise any of these rights, please contact the Data Compliance Manager in writing.

13.3 No fee usually required

You will not have to pay a fee to access your personal information or exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive, or refuse to comply in such circumstances.

13.4 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access. This is another security measure to ensure personal information is not disclosed to any person who has no right to receive it.

14Right to withdraw consent

In the limited circumstances where you may have provided your consent for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Compliance Manager. Once we have received notification, we will no longer process your information for the purpose(s) you originally agreed to, unless we have another legitimate basis for doing so in law.

15Data Protection Officer

We have appointed a Data Compliance Manager to oversee compliance with this privacy notice. If you have any questions about this notice or how we handle your personal information, please contact the Data Compliance Manager at info@oasisumbrella.co.uk. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

16Changes to this privacy notice

This privacy notice is not contractual; we reserve the right to update it at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.