Employee Privacy Policy

Introduction

Data protection principles

• Used lawfully 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; and
• Kept securely

How will we use personal data about you?

1. Where you have consented to us using your Personal Data, such as when you send us your CV with Personal Data contained in it (“Consent”);
2. Where we need to perform the contract we have entered into with you, such as paying you your salary (“Contractual Obligation”);
3. Where we need to comply with a legal obligation, such as reporting fraudulent activity or other illegal actions (“Legal Compliance”); and
4. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests, such as providing a list of our employees to investors as part of a due diligence process; (“Legitimate Interest”).

What categories of your personal data do we collect, store and use?

Below we list all of the categories of Personal Data we collect, store and use.  This data is collected when you apply for employment with us or during or after your employment with us.   Not all of the following types of data will necessarily be collected from you but this is the full scope of team member Personal Data that we collect:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
• Date of birth; Gender;
• Employment history
• Marital status and dependants;
• 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;
• Leaving date and your reason for leaving; Location of employment or workplace;
• Identification (including copy of driving licence, passport or other identity card;  photographs showing face or other identifying features);
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process);
• Employment records (including job titles, work history, working hours, holidays, training records and professional memberships);
• Compensation history; Performance information;
• Disciplinary and grievance information;
• Whistleblowing concerns raised by you, or to which you may be a party or witness;
• 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;
• Medical and health information.

When do we collect your personal data and what is our legal basis for collecting it?

Under the GDPR you are entitled to understand exactly when we collect different categories of your Personal Data and what legal justification we rely on in order to use that Personal Data.

Set out below is a table containing the different categories of Personal Data we collect, when we collect it (e.g. the activity that gives rise to the Personal Data collection) and the lawful basis for collecting, processing and using that Personal Data. Please refer to the section entitled "How Will We Use Personal Data About You?" to understand more about the legal basis we rely on.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described, but we will never process your data without a legal bases for doing so and  it is for a related purpose. For further inquiries please contact our Data Protection Officer.

Change of purpose

We will only use your Personal Data 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 your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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

Failing to provide Personal Data

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 (such as to ensure the health and safety of our team).

Explicit Consent

Where we have stated that we are relying on "explicit consent" for the processing of certain categories of data we will have contacted you for written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. 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.

Sharing personal data with third parties

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your Personal Data outside the United Kingdom or EEA. If we do, you can expect a similar degree of protection in respect of your Personal Data as data resident and processed within the UK or EEA.We will only share your Personal Data with third parties in accordance with the GDPR and as outlined in the legal justification table above.

”Third parties” include:

• Third-party service providers (including contractors and designated agents) and other entities within our group. Examples of the services we may receive from third-parties that would require us to share team Personal Data could include: recruitment services, human resources information system platforms, payroll, pension administration, legal services, insurance such as medical, company shares management platform such as Vestd, IT services, etc.;
• Other entities in our group structure (if applicable);
• Third parties in the context of a possible sale or restructure. 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; and
• We may need to share your Personal Data with a regulator or to otherwise comply with the law. This may include making returns to HMRC or disclosures to shareholders such as directors’ remuneration reporting requirements.

If you would like to know exactly which third parties have been given access to your Personal Data by us, please contact our Data Protection Officer.

Fraud prevention

General

We will check your details against the Cifas databases established for the purpose of allowing organisations to record and share data on their fraud cases, other unlawful or dishonest conduct, malpractice, and other seriously improper conduct (“Relevant Conduct”) carried out by their staff and potential staff. “Staff” means an individual engaged as an employee, director, trainee, homeworker, consultant, contractor, temporary or agency worker, or self-employed individual, whether full or part time or for a fixed-term.

The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and other relevant conduct and to verify your identity.

Details of the personal information that will be processed include: name, address, date of birth, any maiden or previous name, contact details, document references, National Insurance Number, and nationality. Where relevant, other data including employment details will also be processed.

We and Cifas may also enable law enforcement agencies to access and use your personal data to detect, investigate, and prevent crime.

We process your personal data on the basis that we have a legitimate interest in preventing fraud and other Relevant Conduct, and to verify identity, in order to protect our business and customers and to comply with laws that apply to us. This processing of your personal data is also a requirement of your engagement with us.

Cifas will hold your personal data for up to six years if you are considered to pose a fraud or Relevant Conduct risk.

Consequences of processing

Should our investigations identify fraud or any other Relevant Conduct by you when applying for or during the course of your engagement with us, your new engagement may be refused or your existing engagement may be terminated or other disciplinary action taken (subject to your rights under your existing contract and under employment law generally).A record of any fraudulent or other Relevant Conduct by you will be retained by Cifas and may result in others refusing to employ you. If you have any questions about this, please contact us using the details provided.

Data transfers

Cifas may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then Cifas will ensure your data continues to be protected by ensuring appropriate safeguards are in place.

Your rights

Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data, request that your personal data is erased or corrected, and request access to your personal data.

For more information or to exercise your data protection rights, please contact us using the contact details provided.

You also have a right to complain to the Information Commissioner's Office which regulates the processing of personal data.

Data security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Data Protection Officer. If any data is shared to third parties they will only process your Personal Data on our instructions and they are subject to  a duty of confidentiality.

Data retention

We will only retain your Personal Data 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. 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, and the applicable legal requirements.

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

Right of access, correction, erasure and restriction

Your duty to inform us of changes

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

Your rights in connection with Personal Data

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

• Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data 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 Data where you have exercised your right to object to processing (see below).
• Object to processing of your Personal 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. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your Personal Data to another party.

If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact our Data Protection Officer in writing.

No Fee Usually Required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data 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 our Data Protection Officer. 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.

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you  have any questions or complaints about this privacy notice or how we handle your Personal Data, please contact the DPO.

DPO Name: Alan Cathcart

DPO Email: dpo@fintern.ai

Alternatively, if you have a complaint, you may get in touch with our supervisory authority for data protection compliance at www.ico.org.uk: Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

Changes to this privacy notice

We reserve the right to update this privacy notice 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 Data.

IF YOU HAVE ANY QUESTIONS ABOUT THIS PRIVACY NOTICE, PLEASE CONTACT OUR DATA PROTECTION OFFICER.

Version 26-04-2022
Previous versions: 21-02-2022