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).

It applies to all employees, workers and contractors.

Bauer Media Group 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 current workers and contractors. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical via MyBauer.

It is important that you read and retain 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 and what your rights are under the data protection legislation.

The Bauer Media Group in the UK consists of:

Bauer Consumer Media Ltd, whose registered office is at Media House, Peterborough Business Park, Lynch Wood, Peterborough, PE2 6EA. Registered in England and Wales company number 01176085, VAT no. 918 5617 01, ICO no. Z6398598.

And

Bauer Radio Ltd, whose registered office is at Media House, Peterborough Business Park, Lynch Wood, Peterborough, PE2 6EA. Registered in England and Wales company number 01394141, VAT no. 918 5617 01, ICO no. Z2134130.

And

H Bauer Publishing, whose registered office is at The Lantern, 75 Hampstead Road, London NW1 2PL. Registered in England and Wales company number LP003328, VAT no 918 5617 01, ICO no. Z4855366.

2. Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

3. 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 certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. Information about criminal convictions also warrants this 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 dependants.

· Next of kin and emergency contact information.

· National Insurance number.

· Driver’s license.

· Bank account details, payroll records and tax status information.

· Salary, annual leave, pension and benefits information.

· Start date and, if different, the date of your continuous employment.

· Leaving date and your reason for leaving.

· Location of employment or workplace

· Recruitment information (including copies of right to work documentation, copy of passport, 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, holidays, training records and professional memberships).

· Compensation history.

· 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.

· Photographs.

· Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied.

We may also collect, store and use the following more sensitive types of personal information:

· Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.

· Trade union membership.

· Information about your health, including any medical condition, health and sickness records, including:

o where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision;

o details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and

o where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.

· Health Information so we can comply with our legal obligation to protect you from the health risks whilst working.

· Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about employees, workers and contactors 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 employers, credit reference agencies or other background check agencies

We may also collect personal information from the trustees or managers of pension arrangements operated by a group company.

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

4. 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:

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

2. Where we need to comply with a legal obligation.

3. Where it is necessary for legitimate interests pursued by us or 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:

1. Where we need to protect your interests (or someone else's interests).

2. 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 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, 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 or deemed employee for tax purposes, deducting tax and National Insurance contributions (NICs).

· Providing the following benefits to you: Life Assurance, Pensions, Cycle to Work Schemes, Dental Insurance, Medical Insurance, Gadget Insurance, Travel Insurance, Car Parking Arrangements, Health Assessments, Technology Purchase Schemes – this list is not exhaustive and is subject to change depending on the prevailing benefits offered by the Group at the current time.

· Enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties.

· 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.

· To plan career development for our employees and succession planning for the business.

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

· Gathering evidence for possible grievance or disciplinary hearings and to keep records of such processes to ensure acceptable conduct in the workplace.

· Making decisions about your continued employment or engagement.

· To respond to and defend legal claims made against either the company, its assets or its employees.

· To provide references for current and past employees whether it be for future employment or financial related references (for example mortgage references).

· Making arrangements for the termination of our working relationship, including exit interviews.

· Education, training and development requirements.

· Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.

· To ensure effective general HR and business administration, such as access to our IT services; processing expenses; booking travel or accommodation.

· Sending items to your home address, for example cards; flowers.

· To carry out employee surveys across the group.

· Ascertaining your fitness to work.

· Managing sickness absence and our absence management procedure which may include obtaining advice from a medical practitioner.

· Complying with health and safety obligations.

· To prevent fraud.

· To monitor your use of our information and communication systems to ensure compliance with our Acceptable Use Policy for Information Systems.

· To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

· To conduct data analytics studies to review and better understand employee retention and 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.

5. 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).

6. 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.

7. How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Special category data includes the following:

· Race and ethnic origin

· Religious or philosophical beliefs

· Political opinions

· Trade union memberships

· Biometric data used to identify an individual

· Genetic data

· Health data

· Data related to sexual preferences, sex life and/or sexual orientation

We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations or exercise rights in connection with employment.

3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.

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 (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations as an employer

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 and other laws.

· 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 and manage sickness absence and to administer benefits including statutory maternity pay, statutory sick pay, pensions and permanent health insurance.

· If you apply for an ill-health pension under a pension arrangement operated by a group company, we will use information about your physical or mental health in reaching a decision about your entitlement.

· We will use information about your race or national or ethnic origin, religious, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

· We will use trade union membership information to register the status of a protected employee and to comply with employment law obligations.

To record personal sensitive information in the accident book as required by legislation.

8. 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 from us.

9. 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 obligations and 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.

We will only collect 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 or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences in the following ways:

· In relation to driving company vehicles or on company business.

· To comply with relevant corporate governance legislation which may affect certain roles in the business.

· In relation to insurance of the above or any other company funded insurances.

· For managing any work experience placements for the purposes of child safety.

10. Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU.

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my 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 my 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: payroll, pension administration, and benefits provision, fleet management, mobile phone providers, occupational health providers, childcare vouchers, employee survey providers, cycle to work schemes, medical/travel/gadget insurance providers, legal advisors, employee assistance programmes.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group 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 specified purposes and in accordance with our instructions.

When might you share my 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 or group restructuring exercise, for system maintenance support and hosting of data, HR and Finance.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC, Emergency Services, Court Bailiffs, Courts (for Jury Service or Attachment of Earnings Orders), The Home Office or other legal advisors to the company for the purposes of compliance with the law.

Transferring information outside the EU

We may from time to time share data with other Bauer territories for the purposes of reporting or data analysis or for instance if there are any international assignments or secondments. Some of our data providers are based outside of the EU and therefore your data may be transferred in accordance with this policy.

If we have to transfer the personal information outside the EU in order to perform our contract with you. We will ensure that there is an adequacy decision by the European Commission in respect of these countries. This means that the countries to which we transfer your data are deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measure[s] to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection:

If you require further information about these protective measure[s], you can request it from Data Protection Officer.

11. Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request and information can be found (on Media Vine) in the Acceptable Use Policy and Information Security Policy.

Third parties will only process your personal information on our instruction and where they have agreed to treat the information confidentially and to keep it secure.

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 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.

12. Data retention

How long will you use my information for?

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 our retention policy which is available here Media Vine. To determine the appropriate retention period for personal data, we consider 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 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 of the company we will retain and securely destroy your personal information in accordance with our data retention policy OR applicable laws and regulations.

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:

o Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

o Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

o 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. 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 (see below).

o 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

o Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

o 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, please contact the Data Protection Officer 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). However, we may 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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). 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

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 the Data Protection Officer. Once we have received 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.

Data Protection Officer

We have appointed a Data Protection Officer 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 the DPO. 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 via MyBauer. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact either Kerry Jenkins, HR Manager or Susan Voss, Legal and Compliance Director and Data Protection Officer.

Document Control

Document

Bauer Group Employee Privacy Policy

Document Owner

Kerry Jenkins and Susan Voss

Purpose

GDPR Privacy notice for employees, workers and contractors

Audience

Employees, workers and contractors