Last updated

december 7, 2023

General Data Protection Regulation (GDPR) - Privacy Notice 

Introduction 

Mykor Ltd is committed to protecting the privacy and security of your personal information. This Privacy Notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). 

Mykor Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in the Privacy Notice, to enable you to understand how and why we are using personal information about you. It is important that you read this notice, and any other privacy notice provided so that you are aware of how and why we are using such information. 

This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time. 

Data Protection Principle 

We will comply with data protection law. The law states that personal information we hold about you must be: 

● Used lawfully, fairly 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 compatible 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 is necessary for the purposes we have told you about ● Kept securely 

● Inform you of the kind of information we hold about you 

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection. We will collect, store and use the following categories of personal information about you: 

● Personal contact details such as name, title, addresses, telephone numbers and personal email addresses 

● Date of birth 

● Gender 

● Marital status and dependents 

● 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 

● Start date 

● Location of employment or workplace 

● Copy of passport photo page 

● Copy of driving license and car insurance (if applicable) 

● 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 title, work history, working hours, training records and professional memberships 

● Compensation history 

● Performance information 

● Disciplinary and grievance information (if applicable) 

● CCTV footage and other information obtained through electronic means such as fob records 

● Information about your use of our information and communication systems ● Photographs 

We may also collect, store and use the following “special categories) of more sensitive personal information: 

● Information about your race or ethnicity (and religious belief, if relevant) ● Information about your health, including any medical condition, allergies, health and sickness records 

● Information about criminal convictions, including driving/road traffic convictions


Collection of Personal Information 

We collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties, including former employees.

We will collect additional personal information in the course of job-related activities throughout the period you work for us. 


Using Your Personal Information 

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances: 

● When we need to perform the contract we have entered into with you ● Where we to comply with a legal obligation 

● 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 


Situations in Which We will Use Your Personal Information 

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of those or those of a third party, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below: 

● Making a decision about your recruitment or appointment 

● Determining the terms on which you work for us 

● Checking you are legally entitled to work in the UK 

● Paying you and, if you are an employee, deducting tac and National Insurance contributions 

● Providing the following benefits to you: 

● Group medical insurance 

● Pension 

● Company car plan 

● Membership of gyn 

● Online benefit platforms 

● Purchasing gifts and prizes 

● Administering the contract we have entered into with you 

● Business management and planning, including accounting and auditing ● Conducting performance reviews, managing performance and determining performance requirements 

● Making decisions about salary reviews and compensation 

● Assessing qualifications for a particular job or task, including decisions about promotions 

● Gathering evidence for possible grievance or disciplinary hearings 

● Making decisions about your continued employment or engagement

● Making arrangements for the termination of our working relationship

● Education, training and development requirements 

● Dealing with legal disputes involving you, other employees, workers, contractors, including accidents at work 

● Managing sickness absence 

● Complying with health and safety obligations 

● To prevent fraud 

● To monitor your use of our information and communications systems to ensure compliance with our IT policies 

● To ensure network and information security, including preventing unauthorised access to our computer and electronic communication systems and preventing malicious software distribution 

● To conduct data analytics studies to review and better understand employee retenton and attrition rates 

● Business travel 

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. 

The circumstances in which we may process personal data to pursue legitimate interests of the Company are those where it is necessary to ensure: 

That decisions which potentially affect several employees are made, as far as possible, in a balance, fair and objective manner 

That any questions or disputes arising from such decisions are properly addressed and resolved, such circumstances are likely to include decisions about matters such as business management and planning, performance and salary reviews, benefits packages, promotions and training and development requirements 


Failing to Provide Personal Information 

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 health and safety of our workers). 


Change of Purpose 

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need it for another reason and that reason is compatible with the original purpose. If we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.



How We Use Particularly Sensitive Personal Information 

“Special categories” of particularly sensitive information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances: 

In limited circumstance, with your explicit written consent 

Where we need to carry out our legal obligations 

Where it is necessary to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards 

Less commonly, we may process this type of information, where it is needed in relation to legal claims or, where it is needed, to protect your interests and you are not capable of giving your consent or where you have made the information public. 

Our Obligations as an Employer 

We will use your particular sensitive personal information in the following ways: 

Information relating to absences from work, which may include sickness absence or family related leave, may be used for the purpose of complying with employment and other legislation 

Information about your physical or mental health or disability status, may be used for the purpose of ensuring your health and safety in the workplace, assessing your fitness to work, providing appropriate workplace adjustments, monitoring and managing sickness absence and administering benefits 

Information about your race, nationality or ethnic origin may be used for the purpose of equal opportunity monitoring and reporting 

Requiring Consent 

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your 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 with to consent.



Information about Criminal Convictions 

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out obligations and provided we also do so in accordance with our Data standards. 

Where appropriate, we will collect information about criminal convictions if I is appropriate given the nature of the role and where we are legally obliged to do so. 

In some circumstances we may be notified of information about criminal convictions directly by you in the course of working for us. This is likely to apply particularly for driving/traffic offences. 

We envisage that we may hold information about criminal convictions. 

Automated Decision-Making 

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. 

We do not envisage that any decisions will be taken about you using automated means, we will notify you in writing if this position changes. 

Data Sharing 

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

We will not transfer the personal information we collect about you to entities outside the EU without your express consent. If we do, you can expect a similar degree of protection in respect of your personal information. 


Reasons for Sharing with a Third Party 

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have legitimate interest in doing so.

Third-Party Service Providers Processing Information 

“Third-parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: 

● Pension administration 

● Benefits provision 

● Administration (car schemes) 

● IT services 

● Employment law advice 

● Occupational health service 


Third-Party Security 

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for the specified purposes and in accordance with our instructions. 

Other Third Parties 

We may share your personal information with other third parties, e.g. in possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law. 

Data Security 

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors or other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected data security breach and will notify you and applicable regulator of a suspected breach where we are legally required to do so.

Data Retention 

We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available in the Retention Policy. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal date; the potential risk of harm from unauthorised use or disclosure of your personal data; the purposes for which we process your personal date and whether we can achieve those purposes through other means; and the applicable legal requirements. 

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor we will retain your personal information in accordance with our Retention Policy. The information will be securely destroyed at the end of the retention periods referred to in this policy. 

Rights of Access, Correction, Erasure and Restriction Your Duty to Inform Us of Changes 

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

Your Rights in Connection with Personal Information Under certain circumstances, by law you have the right to: 

● Request access to your personal information (commonly known as “data subject access request”) 

● Request correction of the personal information we hold about you ● Request erasure of your personal information, this enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it 

● Object to processing of your personal information 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 

● Request to the restriction of processing your personal information ● Request the transfer of your personal information to another party



If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal date, or request that we transfer a copy of your personal information to another party, please contact your Line Manager in writing. 

No Fee Usually Required 

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). We may, however, 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. 

Right to Withdraw Consent 

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information 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 a Director. 

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 information.