Staff Privacy Notice

Staff Privacy Notice

Introduction

  • This privacy notice describes how Langford Veterinary Services ('LVS' or 'we') collects and uses your personal data and supersedes any previous privacy notices.
  • This notice is to help you understand how and why we collect personal data about you and what we do with that information. It also explains the decisions that you can make about your information.
  • This Notice is aimed at all staff working at LVS (whether directly or indirectly), whether paid or unpaid, whatever their position, role or responsibilities (including employees, work experience/placement students, volunteers and certain contractors and agency staff) and applicants for employment vacancies. This Notice does not form part of your contract of employment (or, in the case of volunteers, the volunteer agreement) and the Notice may be amended at any time.

What is "personal data"?

  • Personal data is information about you and from which you can be identified (either directly or indirectly).
  • This includes your contact details, next of kin and financial information. CCTV images, photos and video recordings of you are also your personal data.

What personal data do we hold about you and how is this obtained?

  • Information about you is gathered during the recruitment process, for example:
    • when you provide information to us, for example, on your application form and during any interviews;
    • when we receive your personal data (from you and third parties) in carrying out pre-employment checks, for example, when we receive references, confirmation of your fitness to work, and your right to work in the UK; and
  • We will hold information about your performance. This includes information about skills, achievements, career progression, performance and disciplinary related matters.
  • We hold and use your financial information, such as your bank details, your salary and pension details.
  • We will hold information about any physical or mental health condition you may have which is disclosed to us during the recruitment process or at any other stage of your involvement with us.
  • Your personal data will be created internally by us during the course of your employment, or whilst you are volunteering with us.
  • Your personal data may be acquired from outside of LVS, such as from the University of Bristol if you are a student on placement with us, or occupational health practitioners or from public authorities such as the police.
  • Clients will also sometimes provide us with your personal data, for example, if a client emails the Service to thank us for the work that you carried out for them.

The purposes for which we use your personal data and the lawful bases

  • We use your information in order to:
    • if you are an employee, make sure that you are complying with your employment obligations and that we are complying with our employment obligations;
    • look after your welfare and development and the welfare and development of others;
    • enable us to comply with our legal obligations, to assist us regarding management and operation of the Veterinary practice, and to advance and protect our interests, objects and reputation; and
    • fundraise, market and promote LVS. For example, by using photographs of our staff on our website or in social media.
  • Our lawful bases for using your personal data are as follows:
    • Contract: We need to use your personal data in order to comply with our contractual obligations and for you to perform your obligations as well. This includes where you have asked us to do something before entering into a contract.  If we do not have a contract with you, for example, if you are a volunteer, we will not rely on the contractual basis to use your information.
    • Legitimate interests: This means that we are using your personal data when this is necessary for our legitimate interests or someone else's legitimate interests.
      • Specifically, we have a legitimate interest in making sure that we are able to enforce our rights against you, for example, so that we take disciplinary action where appropriate, investigating if something has gone wrong and protecting LVS (e.g. if you make a complaint), and promoting and improving LVS.
      • In addition your personal data may be processed for the legitimate interests of others.
    • Public task: when we use your personal data in the course of a work experience placement, this is a public task carried out in the public interest, because it is linked to the education of students.
    • Legal obligation: LVS has to comply with various laws and this entitles us to use your personal data where necessary to do this.
    • Vital interests: In limited circumstances we may use your personal data to protect your vital interests or the vital interests of someone else. For example, to prevent someone from being seriously harmed or killed.

The section below contains more information about our purposes for using your personal data and the lawful bases.

Our purposes and lawful bases in more detail

This section contains more detail about the purposes for which your personal data is used, the applicable lawful basis or bases as well as further information about sources and recipients.  It does not say anything different to what's set out above but goes into a lot more detail.

We have used abbreviations so that you can see which bases we are relying on for each of the purposes described    LI means legitimate interests, CT  means contract, PI means public task, LO means legal obligation and VI means vital interests.  So if we have LI, PI that means we are relying on both legitimate interests and public task for that purpose. 

  • We commonly use personal data for:
    • ensuring that we provide a safe and secure work environment - PI,;
    • if you are an employee, providing employment services (such as payroll) - CT, PI;
    • if you are an employee, to pay you a salary and to provide contractual benefits ;- CT;
    • reimbursing your expenses - CT;
    • providing supervision, training and support - PI;
    • protecting and promoting our interests and objectives - LI, or PI depending on the nature and context of the promotion;
    • personnel, administrative and management purposes and to enable us to meet our legal obligations as an employer. For example, to pay staff and to monitor their performance - CT, LO, PI;
    • safeguarding and promoting the welfare of staff and others.  This includes equal opportunities monitoring - LO,  PI ;
    • making sure that you are complying with your obligations - CT, LO, PI; and
    • fulfilling our contractual and other legal obligations - CT, LO, PI.
  • Some specific examples of when we use your personal data are set out below:
    • We use your personal data to consider your suitability to work in your role at the LVS, for example we will receive references about you. Any references that we provide or receive will be treated as confidential which means that you will not usually be provided with a copy. - LO, PI
    • We will check that you have the right to work in the UK by reviewing your identification documents and keeping copies on your personnel file - LO, PI.
    • We will use your personal data in addressing any performance or disciplinary concerns which arise - PI.
    • We will use your personal data in order to fulfil our duty of care to you and colleagues. This includes using information relating to any medical condition you may have in order to verify fitness to work, monitor sickness absence and comply with our duty of care towards you and others -  LO.
    • We will use your personal data when dealing with complaints and grievances with which you are involved (e.g. from other staff or clients) - PI.
    • We may use your personal data when responding to an incident, for example, if something is published on social media which concerns LVS - PI.
    • If you are a student on a placement with us, we will use your personal data to assess your progress, and report back to the University - PI.
    • We will use your personal data to ensure the security of the site - PI.
    • We often use photographs and video recordings of staff, for marketing and promotion purposes. This will include in in social media and on the LVS website - PI We will ask for your consent if the image is being used.
    • We will also allow external publication of certain media where appropriate (for example, a photograph or article in a local newspaper) - LI.
    • We may use your information when ensuring network and information security, for example, our anti-virus software might scan files containing information about you - PI.
    • We also keep some information indefinitely for archiving purposes (this is known as "archiving in the public interest" under data protection law) and for historical research purposes. This includes our legitimate interest in research; supporting long-term accountability; enabling the discovery and availability of LVS's wider identity, memory, culture and history; enabling the establishment and maintenance of rights and obligations and of precedent decisions; educational purposes; and commercial and non-commercial re-use.  For example, we keep some old photographs so that we have a record of what LVS was like in the past. Information held in our archive may be made publicly available but this would only be done in compliance with data protection laws- (LI, PI).
    • We will use your personal data to take other steps to make sure the site and buildings are safe - PI.
    • We may use your information in connection with legal disputes - PI, LO.
    • We will hold information about any protected characteristics you may have (e.g. a disability). This helps us make reasonable adjustments - PI, LO).
  • Where you are employed by us in order to fulfil our obligations to you as an employer we will need to share your information with medical professionals such as occupational health services, where we are making a referral - CT, PI.
  • Where you are a student, we will share information about you with the University about your progress, achievements, and any disciplinary incidents, including complaints from clients - PI.
  • Occasionally we may use consultants, experts and other advisors (including legal advisors and accountants) to assist us in fulfilling our obligations and to help run LVS properly. We will share your information with them if this is relevant to the work they carry out - LI.
  • In accordance with our legal obligations, we will share information with relevant regulatory bodies, - LO, PI.
  • If you apply to work for us and we offer the position to someone with a Skilled Worker visa instead, we have to keep your contact details and why we offered the position to the successful candidate instead. We may be required to share this information with UK Visas and Immigration (LI, LO, PI).
  • If we employ you we must check if you can work in the UK before you start your employment. In certain circumstances we will have to provide information about you to UK Visas and Immigration to comply with our duties  under the UK's legislation on preventing illegal working.  Additionally, if you are sponsored by us under a Skilled Worker or Temporary Worker visa we will have to provide information about you to UK Visas and Immigration to comply with our duties as a sponsor- LO, PI. 
  • We may share some information with our insurance company to make sure that we have the insurance cover that we need or in connection with an actual or possible claim - LI.
  • We may share your information with benefits providers, for example, to ensure that you are able to take advantage of the benefit (if applicable) - CT, PI.
  • We may need to share information about you with the Health and Safety Executive (a government organisation) if there is a health and safety issue at LVS - LO, PI.
  • If we are dealing with a request for information, query, complaint or grievance (e.g. from a client) we may need share your information with other parties if it is relevant and appropriate to do so. - LO, PI
  • If appropriate, we will share your information with individuals connected to LVS who are exercising their data protection rights, for example, when responding to a subject access request - LO, PI.
  • If ever in the future we are considering restructuring LVS (by way of merger/ transfer or otherwise), we may share your information with the other parties involved and with the relevant professional advisors - LI, LO, PI.
  • We will share personal data about staff (including volunteers) with the relevant statutory agencies if it is appropriate to share this information to investigate allegations of misconduct - LO, PI.
  • On occasion, we may need to share your information with the police for the prevention and investigation of crime or the apprehension or prosecution of offenders. We will only do this in specific circumstances to assist the police with their investigations. - LO, PI. 
  • If appropriate, we will share your personal data with clients where this is related to your professional duties - LO, PI.
  • We may need to share your personal data if there is an emergency, for example, if you are hurt in an accident - LO, PI, VI.
  • If you are an employee, we may need to provide your personal data to a pension provider so that you can benefit from your pension entitlement - CT.
  • We will need to share your information if asked to provide a reference. Please note that references will be provided in confidence and we will not usually provide you with a copy of the reference.  - LI.
  • As you will see from the above, in some cases we will rely on more than one lawful basis above for a particular use of your information. In addition, we may move from one of the lawful bases listed above to another as circumstances change
  • We use contractors to handle personal data on our behalf for the following purposes:
    • We use service providers (known as processors) to handle personal data on our behalf for the following purposes: IT consultants who might access information about you when checking the security of our IT network;
    • we use software, apps and websites to assist us with running the business of LVS; and
    • we use third party "cloud computing" services to store some information rather than the information being stored on hard drives located at the University of Bristol.

CCTV and Video Recordings:

We have CCTV in operation in 2 areas of the site. Both are used for the monitoring of patients. In the Small Animal Hospital no recordings are taken. This footage may be used to monitor and evidence patient recovery. Standard Operating Procedures are in place to prevent identifiable images of individuals being kept. Our Rehabilitation Unit takes video footage of patients. Procedures are in place to make sure individuals are not recorded at any time.

If you have any questions about any of the above, please speak to the Operations and Compliance Manager.

  • We must also comply with an additional condition where we process more confidential or special categories of personal data. These special categories are as follows: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, health information, criminal convictions or offences, and information about sex life or orientation.  When we handle these types of information it will usually be doing so because:
    • it is in the substantial public interest to do so.
    • It is necessary for the purposes of carrying out the obligations and exercising specific rights that we have, or that staff have, in the field of employment, social security or social protection. Social security and protection is concerned with preventing, managing and overcoming situations that adversely affect people's wellbeing.  For example, sometimes this would allow us to disclose your information to third parties such as occupational health services.
    • To protect the vital interests of any person where that person cannot give consent, for example, if they are seriously hurt and are unconscious.
    • It is necessary for the establishment, exercise or defence of legal claims. For example, this allows us to share information with our legal advisors and insurers.
    • For medical purposes. This includes medical treatment and the management of healthcare services.

Transfers of your personal data overseas

  • When LVS sends personal data outside of the UK, we have to consider if the other country has the same level of protection for personal data as there is in the UK. Some countries are considered by the UK Government to have adequate rules and this includes all of the European Economic Area and some other countries, such as, New Zealand, Argentina and Japan.
  • Information stored on physical servers at LVS are stored by the university of Bristol, and these servers are based in the UK.
  • In certain circumstances, we may send your information to countries which do not have the same level of protection for personal data as there is in the UK. We will provide you with details about where we are sending your personal data, whether the country has an adequacy decision and if not, the safeguards which we have in place outside of this privacy notice. If you have any questions about the safeguards that are in place please contact our Operations and Compliance manager, Darran Mason, (darran.mason@bristol.ac.uk).

 

 

For how long so we keep staff personal data?

  • Job applicants; When individuals apply to work at Langford Veterinary Services, there is a legitimate interest to only use the information provided to process their application. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Criminal Records Bureau we will not do so without informing them beforehand unless the disclosure is required by law.

Personal information about unsuccessful candidates will be held for 6 months after the recruitment exercise has been completed, it will then be destroyed or deleted. This information is not shared.

  • Current and former employees; Once a person has taken up employment with Langford Veterinary Services we have a contractual lawful basis to compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment has ended we will retain employee records for 6 years.
  • Locums and Consultants: When we engage the services of locums or consultants we have a contractual lawful basis to hold personal information relating to their engagement. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s engagement with Langford Veterinary Services. Once their engagement has ended, we will retain records for 6 years from last engagement.

 

Processing in line with your rights.

  • Data protection legislation gives you a number of rights in your information. Your rights are as follows:
    • Correction: if information LVS holds about you is incorrect you can ask us to correct it.
    • Access: you can also ask what information we hold about you and be provided with a copy of it. This is commonly known as making a subject access request. We will also give you extra information, such as why we use this information about you, where it came from and what types of people we have sent it to.
    • Deletion: you can ask us to delete the information that we hold about you in certain circumstances. For example, where we no longer need the information.
    • Portability: you can request the transfer of your information to you or to a third party in a format that can be read by computer. This applies where (a) the information has been provided by you; (b) the basis that we are relying on to process your personal data  is consent or contract (please see "Our purposes and lawful bases in more detail" above); and (c) the information is being processed by us on computer.
    • Object: you may object to us using your personal data where:
      • we are using it for direct marketing purposes;
      • the lawful basis on which we are relying is either legitimate interests or public interest task. Please see the section "Our lawful bases for using your personal data" above;
      • if we ever use your information for scientific or historical research purposes or statistical purposes.
    • Restriction: you can request that we restrict how we use your personal data.
  • Our Operations and Compliance manager, Darran Mason, (darran.mason@bristol.ac.uk) can give you more information about your data protection rights. To exercise any of your rights you can submit your request in writing to Darran Mason atdarran.mason@bristol.ac.uk.

Consent

  • We may ask for your consent to use your personal data in certain ways as an alternative to relying on any of the bases in the tables above. For example, we may ask for your consent before taking or using some photographs and videos if the photograph or video is more intrusive and we cannot rely on legitimate interests or it being in the public interest.  If we ask for your consent to use your personal data you can take back this consent at any time.  Any use of your information before you withdraw your consent remains valid. You can speak to our Operations and Compliance manager, Darran Mason, using the darran.mason@bristol.ac.uk if you would like to withdraw any consent given

Further information

  • This privacy notice does not, and is not intended to, give you any rights which you did not already have. For example, it does not give you any additional employment or contractual rights.
  • Contact: If you would like any further information about anything within this notice please contact Operations and Compliance manager, Darran Mason, using the email darran.mason@bristol.ac.uk. 
  • Please speak to Darran Mason if:
    • You would like us to update the information we hold about you; or
    • You would prefer that certain information is kept confidential.
  • There is certain information that you are required to provide to us so that we can enter into a contract of employment with you . This includes your contact details, details of your qualifications, details of your right to work in the UK and your bank details.  If you fail to provide certain information when requested, we may not be able to perform our obligations under the contract of employment or agreement we have entered into with you (such as paying you (including paying your expenses) or providing a benefit).  Alternatively, we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
  • You have a right to lodge a complaint the with the Information Commissioner's Office - ico.org.uk.   If you do have any concerns about how we have handled your personal data we would kindly ask that you contact us in the first instance before you speak to the ICO so that we have an opportunity to put things right.

 

Langford Veterinary Services Ltd is a registered private Company 06798554

Registered Office: Beacon House, University of Bristol, Queen's Avenue, Bristol, England, BS8 1SE

False