People and Culture privacy statement
If you work for MPS, we need to retain and process information about you to enable us to run the organisation and manage our relationship with you effectively, appropriately and lawfully.
This document provides you with information as to how MPS collect and process your personal data if you apply to or work for us. It also provides details of the rights you have in relation to your personal data.
How we use your data
If you apply to or work for us as an employee or a contractor, we will ask you to provide certain personal data. We may also fairly obtain your personal data from other sources, for example through the application and recruitment process from an employment agency or background check provider. We may collect additional information from third parties including former employers, credit reference agencies or other background check agencies. We will also collect additional personal information during the course of your employment with, or engagement by, us.
This data will include your personal contact details (such as name, title, addresses, telephone numbers, and personal email addresses), your date of birth, diversity representation data, marital status and dependants, next of kin and emergency contact information, national insurance number, bank account details, payroll records, tax status information, salary, annual leave, pension and benefits information, start date, location of employment or workplace, recruitment information (including copies of identity documentation, 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, training records and professional memberships), performance information, disciplinary and grievance information, CCTV footage and other information obtained through electronic means such as swipe-card records, information about your use of our information and communications systems and your photograph.
We will process your personal data for the following purposes:
- Where it is necessary to perform a contract we have entered into with you (the legal basis of “performance of a contract”), for example to pay you;
- Where we need to comply with a legal obligation (the legal basis of “compliance with a legal obligation”), for example to check that you are legally entitled to work in the UK and to provide you with your legal employment rights;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (the legal basis of “legitimate interests”), for example to review and better understand employee retention and attrition rates.
We may also need to process information you provide or that we fairly obtain about your criminal convictions and offences (including alleged offences), your health (including any medical condition, health and sickness records), race, ethnic origin, religious beliefs, sexual orientation, political opinions and trade union memberships (“Special Category Data”). We may process your Special Category Data in the following circumstances:
- with your explicit consent (the legal basis of “consent”)
- with your explicit consent (the legal basis of “consent”)
- where we need to carry out our legal obligations or exercise rights in connection with employment (the legal basis of “carrying out the obligations and exercising specific rights in the field of employment”), for example to provide you with contractual sick pay;
- where it is needed in the public interest (the legal basis of “public interest”), such as for equal opportunities monitoring and reporting;
- where it is needed in relation to legal claims (the legal basis of “the establishment, exercise or defence of legal claims”), for example at an employment tribunal.
We retain your personal data including any Special Category Data while you work for MPS and, after you cease working for MPS, for as long as is necessary to fulfil our contractual obligations to you, for applicable legal, accounting, or reporting requirements and to providing you with information at your request (such as references).
How we share and transfer personal data
MPS is an international organisation providing members with services around the world. To assist us, we share personal data with certain companies and organisations outside of MPS (such third party providers of employee benefits, such as pension scheme and payroll administrators), who also process personal data as set out in the How we use your data section above.
If you work for us in a country outside the UK, we will transfer personal data between that country and the UK. Depending on the country, the use of personal data may also be subject to additional rules and regulations.
Your rights in respect of your personal data which we hold
You have various legal rights in relation to your personal data:
- The right to obtain a copy of any of your personal data which we hold;
- The right to request that we correct any of your personal data;
- The right to request that we delete your personal data;
- The right to request a restriction is placed on the processing of your personal data;
- The right to object to the processing of your personal data, including the right to object to marketing;
- The right to ask for personal data you have made available to us to be transferred to you or a third party in machine-readable formats; and
- The right to withdraw any consent you have given us to the processing of your personal data.
These rights are not absolute: they do not always apply and exemptions may be engaged. Please note that, before we are able to provide you with any personal data or correct any inaccuracies, we may ask you to verify your identity and to provide other details to help us identify you and respond to your request. If we do not comply with your request, we will explain why.
For further information or to invoke these rights, please contact the People and Culture Division by emailing [email protected]. MPS’s Data Protection Officer, David Wheeler, can be contacted by emailing [email protected]
Please see MPS’s data protection intranet pages or the Information Commissioner’s website at https://ico.org.uk/ for further information about data protection.