Privacy Notice

Data Protection Privacy Notice (ARAG Employees and Prospective Employees)

We believe you should always know what personal information we collect from you and understand how we use it, ARAG UK are committed to being open and transparent with how we use your personal data. That is the basic purpose of this Privacy Notice.

This Privacy Notice applies to all current and former:

  • Prospective employees
  • Employees
  • Workers
  • Contractors

It also applies to individuals whose personal information has been shared with us, for example as an emergency contact or beneficiary. You should show this notice to anyone else whose details you provide to us.

KEY TAKEAWAYS

We recommend that you read this notice in full, but here are a few key things we hope you take away from it:

  • ARAG UK is an insurer (and reinsurer)
  • ARAG LAW provides legal services
  • We collect personal information from you or a recruitment agency at the point of recruitment; right through to if you are successful and become an employee of ARAG.
  • We may share your personal information with third parties in order to fulfil our legal obligations to you as an employer, for example where using a payroll provider
  • We cannot administer your employment or other relationship with you without your personal information

FULL NOTICE

Key sections to this notice includes:

  • Who we are
  • How we collect your personal information
  • The information we use
  • How we use your information
  • Sharing your information
  • Transferring information outside of the UK
  • Your rights
  • How long will we keep information about you
  • How to make a complaint

WHO ARE WE?

ARAG UK is made up of a mix of different companies. In this Privacy Notice, “ARAG”, “we”, “us”, or “our” refers to the ARAG UK company you have a relationship with and who process your personal information as a result. ARAG are the controller of the personal data that we collect about you.

This means that we are responsible for deciding how we hold and use personal information about you.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information from a variety of sources as described below.

  • From you -You provide us with personal data directly when you apply for a job with us and, if your application is successful, when you complete our employee information forms or correspond with us and in the course of performing your job. We also create some personal data ourselves, for instance, in making notes during an interview process. Where you apply for a vacancy through an agency, that agency will provide us with information about you and that you have supplied to them.
  • From third parties -We obtain data from various sources (individuals and organisations), such as publicly available directories and online resources, your previous employers, your previous education institutions, your emergency contacts, and third-party benefits providers. We also perform background checks on our potential employees. Depending on the job role, these checks can relate to any criminal convictions that you may have and your credit reference history. These checks are necessary under the applicable law and those required for our own policy compliance.

THE INFORMATION WE USE

Type of personal information Description
Personal details including contact information Information that identifies or links to you as an individual such as:
  • your name, postal address, e-mail address, telephone number and date of birth or age
  • Marital status, gender identification
  • National insurance number, vehicle registration number and driving licence details (where applicable for company car schemes and parking benefits)
  • Passport (where applicable for identification purposes)
Financial Financial details such as:
  • Details of salary and benefits
  • Bank/building society / account information
  • Tax information
Special Category Data (sensitive information) We may collect sensitive information such as:
  • Information revealing racial or ethnic origin;
  • Biometric data (where used for identification purposes);
  • Health information (for example, details of medical / sickness records)
  • Sexual orientation
  • Trade union membership
Criminal offence data We may collect information such as Criminal records, including the results of Disclosure and Barring Service (DBS) checks

HOW WE USE YOUR INFORMATION

What we use your personal information for Type of Information collected Our Reasons
Job Application/ Recruitment
  • Name, address, email, contact details, emergency contacts (i.e. name, relationship and home and mobile phone numbers)
  • Biometric data (Your image).
  • Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information.
  • Personal data or sensitive information contained in your application form like - Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs
  • Criminal records information, including the results of Disclosure and Barring Service (DBS) checks.
  • National Insurance number, proof of address and / or proof of identity (like a passport or driving licence)
  • Interview notes, which could contain your personal data or special category data (disclosure of sensitive information)
  • Right to work
  • Bank details
  • Information in applications you make for other positions within our organisation
  • Performance of contract- to take steps to enter into a contract of employment with you
  • For our and your legitimate interest in order progress job application.
  • Employment law – for example checking if individuals are entitled to work in the UK
  • Consent – for example where the candidate wishes to disclose ethnicity, nationality or sexual orientation
Payroll
  • Your salary and payroll information.
  • Details of any benefits
  • Bank/building society
  • National Insurance and tax information
  • Your age, name and address.
  • Details of your pension arrangements
  • Performance of contract- in order to fulfil our employee contractual obligations (for example providing you with your pay slip)
  • Employment law - processing is necessary for the purposes of carrying out obligations as an employer
Absenteeism and employee record
  • Annual leave
  • Sickness and Medical records (including sensitive personal information relating to your mental and physical health)
  • Maternity / paternity
  • Emergency contacts (i.e. name, relationship and home and mobile phone numbers)
  • Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs
  • Performance of contract- for example providing you with the leave you are entitled to as per your employee contract
  • Employment law- for example maintaining records of statutory sick pay and maternity pay
  • Consent – for example where the candidate wishes to disclose ethnicity, nationality or sexual orientation
Training, & Competence Information and records demonstrating training and competence in respect of both compliance and non-compliance subjects / disciplines.
  • Name
  • Email address
  • Learning record, Continuing Professional Development (CPD) points.
  • Employment contract and information retained in the duration of your employment.
  • Performance of contract- to ensure we provide you with the training and competence required for your role.
  • In our legitimate interest, in order to ensure minimum standards have been met.
Facilities and IT
  • Health and safety records / assessments
  • A copy of your driving licence; (where applicable for company car schemes and parking benefits)
  • Your image – for security passes and employee identification
  • CCTV – for building security purposes
  • Details of your time and attendance records (this could also be held on a local drive by your line manager)
  • Information about your use of our IT, communication and other systems, and other monitoring information
  • Performance of contract – to facilitate role agreed to in your employee contract
  • Employment Law - ensuring health, safety and welfare of employees
HR (Human Resources) HR File
  • Internal emails
  • Personal performance development documentation (where applicable)
  • Details of your appraisals and performance
  • Details of your management/improvement plans / disciplinary (if any)
  • Return to work and absence records
  • Return to work forms
  • Payroll information
  • Information on grievances raised by or involving you.
  • Employee contract
  • Personal data sets - Name, personal email address, work email address, medical records, details of your employment, job title, and performance score.
  • Performance of contract- maintain records of employment and other HR required documentation.
  • Employment law- for example maintaining records of statutory sick pay and maternity pay

SHARING YOUR INFORMATION

We may share your personal information with other parties, such as:

  • Our group companies for the management of our business
  • Third party service providers (for payroll, benefits administration etc)
  • Your current/past employees and education institutions
  • HMRC for tax purposes
  • Police, regulatory bodies and courts where we are required to disclose your personal data to comply with the law
  • Our legal and financial advisors
  • Potential buyers in the event that we sell all or part of our business as part of a merger or acquisition

TRANSFERRING INFORMATION OUTSIDE OF THE UK

Your information may be transferred outside of the UK for processing, storage, administration or any other use stated in this notice. The processing of any information outside the UK will comply with UK data protection laws or equivalent.

Where it is necessary to send your personal information outside of the UK steps will be taken to make sure appropriate safeguards are in place to ensure the safety and privacy of your information as set out in this privacy notice

YOUR RIGHTS

Under data protection law you may have certain rights we need to make you aware of. The rights available to you depend on our reason for processing your information. You have the right to:

  1. The right to be informed
  2. The right of access
  3. The right to rectification
  4. The right to erase
  5. The right to restrict processing
  6. The right to data portability
  7. The right to object
  8. Rights in relation to automated decision making and profiling.

Please note, these rights are not absolute and there may be times when we cannot do what you ask us to. If that’s the case, we’ll explain why when we reply to you. If you have a question about this Privacy Notice, how we use your personal information, or if you’re not happy with how we process your information, please contact the Data Protection Officer at: [email protected] or [email protected]

HOW LONG WILL WE KEEP INFORMATION ABOUT YOU

We will only retain and use your personal information where it is necessary to comply with our legal obligations, employment law, to resolve grievances or internal investigations, and enforce our agreements. Please refer to our internal Data Retention and Disposal Policy for more information regarding retention periods.

Recruitment -unsuccessful candidates, we will hold your data for 12 months following the end of the recruitment process.

HOW TO MAKE A COMPLAINT

If you have any questions or concerns about the way we process your personal information please contact us by emailing: [email protected] or [email protected] or writing to:

Data Protection Officer
ARAG Legal Expenses Insurance Company Ltd
4A Greenway
Bedwas House Industrial Estate
Bedwas
Caerphilly
CF83 8DW

If you’re not satisfied with the outcome of your query, you can contact the Information Commissioner’s Office by visiting https://ico.org.uk/ or by post to:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

This privacy notice was last updated on 19th July 2022