1.1 CORA Group and it’s parent company, Jonas Computing (UK) Limited and all of its subsidiaries registered in England and Wales and Scotland, Gladstone Limited and any subsidiaries registered in England and Wales, Shortcuts Software (UK) Limited and any subsidiaries registered in England and Wales and Jonas Software Ireland Limited and all of its subsidiaries and SOFTDOC NETWARE. S.L.U registered in Spain, Book assist España S.L.U. registered in Spain, Automatic Netware Italia S.R.L. registered in Italy, Book assist Italia Srl registered in Italy, Book assist Czech Republics.r.o registered in the Czech Republic, Book assist Austria Gmb registered in Austria (together known as “CORA”, “Jonas”, “we”, “our”, and “us”) are committed to ensuring that your privacy is protected. This privacy notice explains how we process personal data concerning our employees, workers, independent contractors and candidates who apply for roles with us (“you”, “your”). It applies to current and former employees (“Employees”),current and former workers (“Workers”) and current and former independent contractors (“Contractors”).
1.2 This notice sets out what personal data we collect, why we collect it, how we use it and the legal basis for doing so and the procedures we have in place to protect your personal data. It is important to read this notice, together with any other privacy policy we may provide in specific circumstances when we are processing your personal data, so that you are aware of how and why we are using your information.
1.3 This notice does not form part of any contract of employment or other contract for services and may be amended from time to time in accordance with section 22.
2.1 Jonas Computing (UK) Limited (a limited liability company registered in England and Wales under number 05301607), Gladstone Limited (a limited liability company registered in England and Wales under number 03327360 ) both with a registered office at Gladstone House, Hithercroft Road Wallingford, England OX10 9BT and Jonas Software Ireland Limited and all of its subsidiaries. Shortcuts Software (UK) Limited (a limited liability company registered in England and Wales under number 04384547). SOFTDOCNETWARE. S.L.U. at Calle Joaquin Bau, 2 BJ AB, 28036 Madrid (Spain), Book assist España S.L.U. at Calle Joaquin Bau, 2 BJ AB, 28036 Madrid (Spain) Automatic Netware Ltd., trading as Book assist, 1st Floor, South Block, Rockfield Central, Dundrum, Dublin D16 R6V0, Ireland (Ireland), Automatic Netware Italia S.R.L. at Piazza Luigi di Savoia, 22 – 20124 Milano (Italy), Book assist Italia Srl at Piazza Luigi di Savoia, 22 – 20124 Milano (Italy), Book assist Czech Republics.r.o at Praha 1, Ovocný trh 1096/8, Post code:110 00, Czech Republic (Czech Republic) Book assist Austria Gmb at Mariahilferstraße 136/2.05, 1150 Wien(Austria).
2.2 Jonas is a data controller of the personal data of its Employees, Contractors, Workers and candidates. This means that we are responsible for deciding how we hold and use personal data about you.
Questions about your personal information:
If you have any questions about this privacy notice or your information, or to exercise any of your rights as described in this notice or under applicable data protection laws, you can contact the HR team at:
JonasGroup UK
Hithercroft Road
Wallingford
Oxfordshire
OX109BT
By email:UKHRSupport@jonassoftware.co.uk
By telephone: 01491 201010 (option 8)
3.1 Anyone processing personal data must comply with the principles of processing personal data. We set out these principles below along with our procedures for complying with such principles:
4.1 We collect the personal data of our Employees, Workers and Contractors to operate our business and manage them, to monitor performance and to comply with our legal and regulatory obligations as employers.
4.2 We collect personal data from our candidates to assist with our recruitment processes and to monitor recruitment statistics.
4.3 We set out below a list of the categories of information we may collect from Employees, Workers, Contract or sand candidates. We aim to make this list as comprehensive as possible but it is not exhaustive. The information that we collect includes, but is not limited to, the following:
4.4 We also collect data derived from our IT and communications monitoring in relation to our Employees, Workers and Contractors including:
4.5 Further detailed information about IT and communications monitoring, and the purposes for such monitoring, can befound in our policies and procedures.
5.1 Some of the personal data we collect(as described in section 4), and additional information, may be provided to us by recruitment agencies with whom you have registered an interest. Such recruitment agencies support our recruitment processes under a duty of confidentiality.
5.2 During the recruitment process we may also research information regarding your skills, experience or qualifications and comments and opinions made public on social networking sites such as LinkedIn, Facebook and Twitter.
5.3 We also receive other information about you from organisations such as credit reference agencies, fraud prevention agencies and referees.
6.1 You may also supply us with, or we may receive, sensitive personal data relating to your racial or ethnic origin, genetic and biometric data, political opinions, religious or philosophical beliefs, trade union membership or data concerning your health or data concerning your sex life or sexual orientation.
6.2 We will use this information for the purposes of defending and bringing legal claims, either performing our contractual obligations or exercising obligations or rights which are imposed or conferred on us by law in connection with our obligations as an employer including:
6.3 In relation to Workers, Contractors and Employees, we may also collect sensitive personal data about your physical or mental health (including contained in sickness records) and information about your physical or mental health or condition in order to monitor sick leave and take decisions as to your working capacity and for occupational health purposes.
6.4 We may also collect genetic and biometric data to enable us to allow you to access our building(s) to enable you to undertake your specific duties under the contract of employment or contract for services.
6.5 We may also process data which has been made manifestly made public by you or with your explicit consent.
7.1 We also collect, store and otherwise process personal data relating to criminal convictions and offences (including the alleged commission of offences).
7.2 This data is only processed where it is necessary for the purposes of:
8.1 The information about you which is obtained by us during the application process and during the course of your employ mentor contract for services (whether obtained directly from you or from third parties) may be used by us for the following purposes:
8.2 Information we obtain from our IT and communications monitoring in relation to Employees, Workers and Contractors is used for compliance with our legal and regulatory obligations, for quality assurance and training purposes and for prevention or detection of any unlawful acts, and for establishing, exercising or defending legal rights.
8.3 Your information will not be used for other purposes without your permission, save as required by applicable law.
9.1 The legal basis for our processing of your personal data is based on the fact that you are an Employee, Worker, Contractor or a candidate and it is necessary for us to process your information as follows:
| Purposes for which we will process the information | Legal Basis for the processing |
|---|---|
| • to consider your application in line with our recruitment purposes; | • It is in our legitimate interest to recruit Employees, Workers and Contractors and to select the best candidates. We consider this to be necessary for our legitimate interests and will not be prejudicial or detrimental to you. |
| • to carry out background and reference checks, where applicable; | • It is in our legitimate interests to assess the suitability of candidates and Employees, Workers and Contractors. We consider this to be proportionate and will not be detrimental to you. |
| • for administrative purposes in connection with your employment contract or contract for services; | • It is necessary to comply with our legal obligations as an employer. In addition, it is necessary to comply with our contractual obligations to our Workers and Contractors. It is also in our legitimate interests and will not be prejudicial or detrimental to you. |
| • to undertake business analysis activities; | • It is in our legitimate interests to manage and monitor our human resources function. We consider this to be necessary for our legitimate interests and will not be prejudicial or detrimental to you. |
| • to monitor Employees and Workers’ performance; and | • It is in our legitimate interests to monitor our Employees and Workers and performance levels. We consider this to be necessary for our legitimate interests and will not be prejudicial or detrimental to you. |
| • to comply with our legal and regulatory obligations. | • It is necessary to comply with our legal and statutory obligations as an employer and service provider. |
9.2 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 Employees, Contractors and Workers).
9.3 The legal basis for our processing of any special categories of (sensitive) personal data is based on the fact that you are an Employee, Worker or Contractor or a candidate and it is necessary for us to process such information to comply with our legal obligations, namely:
9.4 We also process special categories of(sensitive) personal data where necessary for the establishment, exercise or defence of legal claims.
10.1 For the purposes set out in section 8above, we share information concerning our Employees, Workers and Contractor swith:
10.2 We also share your information with the following third parties in connection with your benefits. These third parties will also be data controllers of your personal data and your personal information will be processed in accordance with the third party’s privacy policy with which you should familiarise yourself:
You have been notified of the identity of the relevant benefit providers and any changes or additions will be communicated to you by email or other appropriate method.
10.3 For the purposes set out in section 8above, we may share information concerning candidates with other authorised Employees.
10.4 We will also disclose personal information concerning Employees, Workers and Contractors and candidates to other third parties where there is a legitimate reason to do so including for the following reasons:
10.6 We will also disclose your personal information to third parties who have made a request for a reference either during or following the end of your contract for services or contract of services. As it is not reasonable for us to contact you to ask for consent on every occasion that we receive a reference request please let us know if you object to our processing your data for the purposes of providing a reference.
11.1 In connection with the administration of your medical health insurance, child care voucher scheme, pension scheme and group life cover we may collect your family members’ (such as a parent, grand parent, great-grandparent, child or sibling) personal data and data concerning the health of your family members. We may also collect family members’ personal data for administrative purposes in connection with the operation of your employment contract or contract for services using “next ofkin” forms.
11.2 As it is not reasonable for us to contact and obtain consent from such family members to the processing of their data, please let us know if any such family member objects to us processing their data for the purposes of sharing it with the relevant insurer or third party or us. In the case of children under the age of 13, consent should begiven by someone with parental responsibility for them. You are requested to ensure that you notify human resources of any changes to such information without undue delay.
12.1 We will take reasonable steps to try to ensure that your information is kept accurate and up-to-date. However, all Employees, Workers, Contractors and candidates are requested to ensure that human resources are notified of any changes to their personal information without undue delay.
12.2 Where you have notified human resources or we otherwise become aware of an inaccuracy in your personal information, we will take every reasonable step to ensure that the informations either erased or rectified without delay.
13.1 We implement a number of additional policies in relation to data privacy and data security. You are referred in particular to the Group Data Protection Policy which sets out your rights and obligations in relation to data protection.
13.2 Please familiarise yourselves with these additional policies. If you have any questions about such policies and procedures you should speak to your line manager. These policies may be updated from time to time. Any new or updated policies or manual will be communicated to you by email or any other appropriate method.
14.1 You have the following rights:
14.2 You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on our legitimate interests. In such event we shall no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests or for the establishment, exercise or defence of legal claims.
14.3 If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing for such marketing.
14.4 Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.
15.1 You can exercise any of your rights as described in this notice and under data protection laws by contacting your line manager or human resources.
15.2 Save as provided under applicable data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee (subject to any limits imposed by applicable law) taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.
15.3 Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.
16.1 We store your personal data in hardcopy and electronic format. We use appropriate technical and organisational safeguards to protect personal data both online and offline from un authorised use, loss or destruction. We use physical and procedural security measures to protect information from the point of collection to the point of destruction. This includes encryption, pseudonymisation, firewalls, access controls, policies and other procedures to protect information from unauthorised access.
16.2 Only authorised personnel and third party service providers are permitted access to personal data, and that accessis limited by need. We will only transfer personal data to a third party if it agrees to comply with those procedures and policies, or if it puts in place adequate measures itself.
16.3 Despite these precautions, however, Jonas cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal data. In the event of a data breach, Jonas have put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.
17.1 As part of an international Group, it is necessary to transfer and store your personal data to locations outside ofthe European Economic Area (“EEA”) as follows:
17.2 Where personal data is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for personal data, we take steps to provide appropriate safeguards to protect your personal data, including:
17.3 If you want further information on the specific mechanism used by us when transferring your personal data out of the EEA, please contact us using the details set out above.
18.1 We will retain the information we collect about Workers, Employees and Contractors in your personnel file for the course of your employment or contract for services. Following the end of employment or contract for services we will retain your personnel file for as long as necessary and permitted for legal, regulatory, fraud and other financial crime prevention and legitimate business purposes. After this period, your personal data will be destroyed.
18.2 For candidates, if your application is successful and you subsequently become employed by us, the information will become part of your personnel file in accordance with section 18.1.
18.3 Personal data about unsuccessful candidates will be held for up to 12 months after the recruitment exercise has been completed. It will then be destroyed or deleted. We may retainde-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.
19.1 We do not use automated decision making to make decisions about our candidates, Workers, Employees or Contractors.
20.1 We use HR Software and reporting systems (including Workday) to manage employee data and as a method of communication with Employees, Workers and Contractors working for some of the Jonas businesses.
20.2 We use various systems to communicate with Employees, Workers and Contractors including Microsoft Outlook and Google Suite for email communications with Employees, Workers and Contractors. We encourage Employees, Workers and Contractors to be familiar with the relevant privacy policy and terms of service when beginning to use these systems. These systems may use cookies, which you are able to opt out of.
20.3 We use other tools to communicate with Employees, Workers and Contractors informally including Slack, Skype and Yammer. We encourage Employees, Workers and Contractors to be familiar with the relevant privacy policy and terms of service when beginning to use these systems. These systems may use cookies, which you are able to opt out of.
21.1 If you have concerns about our use of your personal data, please send an email with the details of your complaint to your local HR Advisor at UKHRSupport@jonassoftware.co.uk.
21.2 You also have the right to complain to the Information Commissioner’s Office (https://ico.org.uk/).
22.1 This notice will be reviewed and, if appropriate, updated from time to time. We will communicate any updates by email or any other appropriate method.
22.2 This privacy notice was last reviewed and updated on 22nd May 2018.
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