Privacy Notice - Lindum Group

Privacy Notice

What Is The Purpose Of This Document?
The Lindum Group Limited (‘we’), are 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 UK General Data Protection Regulation (UK GDPR).
It applies to all employees, workers, contractors, clients and other individuals interacting with the business from here on in referred to as ‘you’ or ‘your’.

Lindum Group Limited 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 this privacy notice. This notice applies to potential, current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data Protection Principles
We will comply with data protection Law, which means the 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 incompatible 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 necessary for the purposes we have told you about.
Kept securely.

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 the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection.
We may collect, store, and use the following categories of personal information about you:

Personal contact details such as; name, title, address, telephone numbers, & personal email address.
Date of birth & Gender.
Marital status & dependants.
Next of kin & emergency contact information.
National Insurance number, Bank account details, payroll records & tax status information.
Salary, annual leave, pension & benefits information.
Start date & location of employment or workplace.
Driving licence information including details of any offences, fines & penalties
Recruitment information (including copies of right to work documentation, copies of passports, ID Cards & visas, references & other information included in a CV, cover letter or as obtained in the application process).
Employment records (including job titles, work history, working hours, time and attendance records)
Training records, Learning Agreements & professional memberships.
Remuneration & Compensation history.
Performance Review, Disciplinary & Grievance information.
Photographs, CCTV footage & audio recording
Information about your use of our information and communications systems.

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

Information about your health, including any medical condition, health and sickness records.
Information about criminal convictions and offences.
Trade union membership.
Information about your gender identity, disability status, race or ethnicity, religious beliefs, sexual orientation and political opinions.

How Is Your Personal Information Collected?
We collect personal information about you through the application and recruitment process, either directly from candidates, an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies. We may collect additional personal information in the course of job-related activities throughout the period of you working for us.

How We Will Use Information About You
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;

Where we need to perform the contract we have entered into with you.
Where we need 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.

We may also use your personal information in the following situations, which are likely to be rare:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest or for official purposes

Situations In Which We Will Use Your Personal Information
We need all the categories of information in the list above (see ‘The kind of information we hold about you’) 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 our own or those of third parties, 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 &, if you are an employee, deducting tax & National Insurance contributions.
Providing benefits to you.
Liaising with your pension provider.
Administering the contract we have entered into with you.
Business management & planning, including accounting & auditing.
Conducting performance reviews, managing performance & determining performance requirements.
Making decisions about salary reviews & remuneration.
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 & development requirements.
Dealing with legal disputes involving you, or other employees, workers or contractors, including accidents at work.
Ascertaining your fitness to work.
Managing sickness absence.
Complying with health & safety obligations.
To prevent or investigate potential fraud.
To monitor your use of our information & communication systems to ensure compliance with our IT policies.
To ensure network & information security, including preventing unauthorised access to our computer or electronic communications systems & preventing malicious software distribution.
To conduct data analytics studies to review & better understand the demographic of the business & employee retention / attrition rates.
Equal opportunities monitoring.

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

What If You Fail 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 the 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 to use 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
Our obligations as an employer means we will use your particularly sensitive personal information in the following ways:

We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment & other laws, to conduct capability reviews, Group restructuring or redundancy activities.
We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor & manage sickness absence and to administer benefits.
It may be necessary to use information about age, gender identity, disability status, race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equality and diversity monitoring & pay gap reporting.
It may be necessary to use trade union membership information to pay trade union premiums, register the status of a protected employee & to comply with employment law obligations.

Do We Need Your 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 wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for 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 our statutory & contractual obligations, provided we do so in line with our data protection policy. Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We envisage that we will hold information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process, periodically through employment or we may be notified of such information directly by you in the course of you working for us.
Automated Decision-Making
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

DATA SHARING

Why Might We Share Your Personal Information With Third Parties?

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 another legitimate interest in doing so.
Which Third-Party Service Providers Process Your Personal Information?
”Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: pension administration, benefits provision and administration, provision of insurance or medical assessment.

How Secure Is Your Information With Third-Party Service Providers And Other Entities In Our Group?
All third-party service providers and other entities in the group are required to take appropriate security measures to protect personal information in line with our policies. We do not allow third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When Might We Share Your Personal Information With Other Entities In The Group?
We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation, group restructuring or redundancy exercise, for system maintenance support and hosting of data.

What About Other Third Parties?
We may share your personal information with other third parties, for example with a regulator or to otherwise comply with the law.

DATA SECURITY
We have put in place appropriate security measures to prevent 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 and 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 any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION
How Long Will We Use Your Information For?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for eg satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we have considered the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise 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 of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your Duty To Inform Lindum Group 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, request a correction of the personal information that we hold about you and request erasure of your personal information. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing or request the restriction of processing of your personal information. You can also 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 data, or request that we transfer a copy of your personal information to another party, you must contact a member of the Lindum HR Team who will provide the relevant guidance including the required procedure for submitting a formal request.
We may need to request specific information from you to help us confirm your identity and ensure your right to exercise such a request. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT
Where you may have provided specific consent to the collection, processing and transfer of your personal information for a specified purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact a member of the Lindum HR Team who will provide the relevant guidance including the required procedure for submitting a formal request to withdraw consent.
Once we have received formal notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

RIGHT TO COMPLAIN

Under the Data (Use and Access) Act 2025, individuals have a statutory right to raise complaints directly with a data controller if they consider that data protection legislation has been infringed because of the way their personal information has been handled (or the personal information of someone they’re acting on behalf of). This may include or the way a data subject access request (DSAR) is being/has been handled or how it has been responded to. The Company’s GDPR Complaints Procedure PR/37/85 sets out how to make a complaint and how this will be
handled. Data subjects are still free to complaint to the ICO directly at any time.

DATA PROTECTION OFFICER
Robbie Kok has been appointed as Lindum Group Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact Robbie in writing. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

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.

You can contact us at info@lindumgroup.co.uk Please keep us informed if your personal data changes.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.