Optimum is aware of its obligations under the General Data Protection Regulation (GDPR) and current data protection legislation, and is committed to processing data securely and transparently. This privacy statement sets out, in line with data protection obligations, the types of data that we hold on Customers, Supply Chain Partners, Job Applicants, those who are visiting our website, and anyone elsewhere we would be processing personal information in line with data protection legislation.
Data controller details
Optimum is a data controller, meaning that it determines the processes to be used when using your personal data. Optimum has appointed a Data Protection Officer who is responsible for overseeing compliance with this policy for the following companies:
- Optimum Drywall Systems Ltd
- Optimum Combined Services Ltd
The Data Protection Officer for these companies is:
Optimum Drywall Systems Limited
Unit 7a Eastpark Trading Estate
Tel: 0117 952 1300
Data protection principles
In relation to your personal data, we will:
- Process it fairly, lawfully and in a clear, transparent way
- Collect your data only for reasons that we find proper for the course of your engagement in ways that have been explained to you
- Only use it in the way that we have told you about
- Ensure it is correct and up to date
- Keep your data for only as long as we need it
- Process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.
Types of data we might hold
The information could be a mixture of personal data and special category data, where special category data is collected it will be treated with strict confidentiality. The data may include information relating to:
- Personal details including your name, title, address, telephone number, bank details, date of birth, national insurance number, email address, gender, qualifications
- photograph ID
- Next of kin (emergency contact) and their contact numbers
- Medical or health information including whether or not you have a disability
- Information included on your CV including references, education history and employment history
- Documentation relating to your right to work in the UK
- Driving licence
- Tax codes
- Letters of concern, formal warnings and other documentation with regard to any disciplinary proceedings or, in the case of workers, confirmation of other discussions about your conduct
- Internal performance information including measurements against targets, formal warnings and related documentation with regard to capability procedures, appraisal forms or, in the case of workers, confirmation of other discussions about your performance
- Leave records including annual leave, family leave, sickness absence etc
- Details of your criminal record
- Training details
- CCTV footage
How we collect your data
We collect data about you in a variety of ways and this will usually start when we undertake to enter into a contract with you where we will collect the data from you directly.
This includes the information you would normally include in a CV or a recruitment cover letter, or notes made by our recruiting officers during a recruitment interview. Further information will be collected directly from you when you complete forms at the start of your employment/engagement, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
In some cases, we will collect data about you from third parties, such as intermediaries who may act as an introducer. Personal data is kept in personnel files or within the Company’s HR and IT systems.
Why we process your data
The law on data protection allows us to process your data for certain reasons only:
- In order to perform the contract that we are party to
- In order to carry out legally required duties
- In order for us to carry out our legitimate interests
- To protect your interests
- Where something is done in the public interest and
- Where we have obtained your consent.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data. For example, we need to collect your personal data in order to:
- Carry out the contract that we have entered into with you and
- Ensure you receive payment.
We also need to collect your data to ensure we are complying with legal requirements such as:
- Ensuring tax and National Insurance is paid
- Carrying out checks in relation to your right to work in the UK and
- Making reasonable adjustments for disabled individuals.
We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:
- Making decisions about who to offer initial employment/engagement to, and subsequent internal appointments, promotions etc
- Making decisions about salary and other benefits
- Providing contractual benefits
- If you are an employee, effectively monitoring both your conduct and your performance and to undertake procedures with regard to both of these if the need arises
- If you are an employee, offering a method of recourse for you against decisions made about you via a grievance procedure
- Assessing training needs
- Implementing an effective sickness absence management system including monitoring the amount of leave and subsequent actions to be taken including the making of reasonable adjustments
- Gaining expert medical opinion when making decisions about your fitness for work
- Managing statutory leave and pay systems such as maternity leave and pay etc
- Dealing with legal claims made against us
- Preventing fraud
Special categories of data
Special categories of data are data relating to:
- Ethnic origin
- Trade union membership
- Genetic and biometric data.
We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
- You have given explicit consent to the processing
- We must process the data in order to carry out our legal obligations
- We must process data for reasons of substantial public interest
- You have already made the data public.
We will use your special category data:
- For the purposes of equal opportunities monitoring
- In our sickness absence management procedures
- To determine reasonable adjustments
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
Criminal conviction data
We will only collect criminal conviction data where it is appropriate given the nature of your engagement with us and where the law permits us. This data will usually be collected at the engagement stage, however, may also be collected during the engagement. We use criminal conviction data in the following ways:
- DBS Checks
- 6-monthly Driving Licence Points Checks
We process this data because of our legal obligation to perform or exercise employment law obligations or rights’
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out our duties in line with your contract with us. If you do not provide us with the data needed to do this, we will be unable to perform those duties eg ensuring you are paid correctly. We may also be prevented from confirming, or continuing with, your engagement with us in relation to our legal obligations if you do not provide us with this information e.g., confirming your right to work in the UK or, where appropriate, confirming your legal status for carrying out your work via a criminal records check.
Sharing your data
Your data will be shared with colleagues within Optimum where it is necessary for them to undertake their duties. This includes, for example, the payroll department for administering payment under your contract.
We may share your data with third parties, when necessary in order to obtain references for you as part of our recruitment process.
We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us.
We do not share your data with bodies outside of the European Economic Area.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such for example our Data Transfer Policy.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with current data protection requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
- technical information, for example, the type of device (and its unique device identifier) you use to access our site, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform;
- information about your visit to our site including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
We process your data for purposes arising from your use of the website, for example, to ensure that we understand who uses our site and how our site is used and to improve our site and ensure it is secure. This processing occurs because it is necessary to meet our legitimate interests in operating and improving the website, analysing its use, and ensuring its security. We will only use your data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related reason and that reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent to use it for that new purpose.
Third party websites
Our site may contain links to and from various third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it, which will be at least for the duration of your engagement with us though in some cases we will keep your data for a period after your engagement has ended. Retention periods can vary depending on why we need your data, as set out in our data retention policy
Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
- The right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
- The right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request. You can read more about this in our subject access request policy which is available from the HR Department
- The right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
- The right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
- The right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- The right to portability. You may transfer the data that we hold on you for your own purposes
- The right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
- The right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so. If you wish to exercise any of the rights explained above, please contact the HR Department.
Making a complaint
The supervisory authority in the UK for data protection matters is the Information Commissioner’s Office (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.
Changes to this policy
Any changes we may make to our privacy statement in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy statement