1. Introduction

This employee privacy notice (or fair processing notice) has been issued by VIVO Defence Services Limited (hereafter "VIVO", "us", "we" or "our") in order to help you understand how VIVO collects, uses, discloses, and safeguards the personal information of our employees.

VIVO is deeply committed to protecting the personal data of our employees and maintaining the privacy of those whose information we handle in the course of our business is one of the key principles in our Code of Conduct.

The purpose of this document is to notify you of the following:

  • The type of personal data which we will collect;
  • The manner in which we will collect that personal data;
  • The reason why we need to collect that personal data;
  • How we will keep your personal data secure;
  • Who we may share your personal data with; and
  • How long we will retain your personal data.

 

2. What type of Personal Data will we collect?

In order to facilitate and manage all aspects of your employment with us, it may be necessary for us to collect and use the following personal information about you:

  • Name and contact information, including your home address, home telephone number and email
  • Date of birth.
  • Gender.
  • Government-issued identification numbers (e.g., National Insurance number).
  • Immigration, right-to-work and residence status.
  • Education, qualification, training, and career history including curriculum vitae.
  • Data regarding an employee’s health or disability (where appropriate).
  • Details of emergency contact/next of kin.
  • Bank details.
  • Biometric identifiers, including finger printing and facial recognition (where appropriate).
  • Criminal record check (where appropriate).
  • Facial images (Photographic images and images obtained via a CCTV system).

Please note that the above is not intended to be an exhaustive list and the type of Personal Data collected about individual employees will differ depending on the role the individual holds within the organisation.

 

3. How will we collect your Personal Data?

We will collect information directly from you during the pre-employment/on-boarding stage and throughout your employment with us. We may also receive information about you from third parties, (e.g. references from previous employers or from our employee screening service providers).

We may also collect your data via our IT systems. Personal data may also be created by us (e.g. your personnel record)

 

4. Why do we collect your Personal Data?

We will process your Personal Data to the extent that it is necessary for us to manage all aspects of your employment with us. Your Personal Data will be processed by us for the following reasons as defined within relevant Data Protection legislation:

 

To enable us to manage your employment contract with us.

This could include but is not limited to:

  • Providing remuneration and benefits (including pensions).
  • Functions relating to recruitment, promotion, training, or career development.
  • Enabling and managing access to corporate assets and premises.
  • Facilitating HR functions including the management of grievances, disciplinary processes, occupation health management and workforce planning.
  • Contacting next of kin and/or arranging medical attention in connection with the death, illness, or injury of an employee in the workplace.

 

Situations where VIVO is under a legal obligation to disclose staff personal data to a third party.

This could include but is not limited to the disclosure of employee personal data in relation to:

  • Payment of tax, National Insurance contributions or other statutory benefits.
  • Confirmation of an employee’s right to work status.
  • Equal opportunities monitoring.

 

Situations where it is in VIVO’s legitimate interests to process employee personal data, including special category information.

This could include but is not limited to:

  • Enabling operational/commercial relationships with clients, suppliers, and sub-contractors;
  • Using biometric controls (e.g. finger printing or facial recognition) to monitor employees access to and the security of restricted areas;
  • To support business and administration functions;
  • Ensuring network and information security, including preventing unauthorised access to computers and electronic communications systems and preventing malicious software distribution;
  • Marketing and communications; and
  • Any other purpose necessary in the interests of business continuity.

Special categories of 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:

  • Where we have your explicit consent to do so - including where you voluntarily provide us with that personal information.
  • Where we need to carry out our legal obligations or exercise rights in connection with your employment.
  • The processing is necessary for establishment, exercise or defence of legal claims.
  • Where it is needed for reasons of substantial public interest, such as for equal opportunities monitoring, in relation to our occupational pension scheme or preventing or detecting unlawful acts such as fraud.

Less commonly, we may process and share this type of information where it is needed to protect your vital interests (or someone else's vital interests) and you are not capable of giving your consent, or where you have made that personal information public. We may also process such information about employees or former employees in the course of legitimate business activities with the appropriate safeguards.

 

5. How will we keep your personal data secure?

As an employee of ours your privacy is important to us, and we are committed to keeping your personal data secure. Your HR personal data is processed by VIVO within the EEA.VIVO takes precautions including administrative, technical, and physical measures to safeguard your personal information, including documented employee procedures, internal monitoring, and training to help ensure that your information is protected and secure.

 

6. Who will we share your Personal Data with?

We will only disclose personal information to a third party in limited circumstances, including where the third party is providing a service to us as a data processor or where we are permitted to do so by law. The third parties we may share your personal data with include:

  • Other organisations within our shareholders’ group of companies, where such disclosure is necessary for our business.
  • Third parties who help manage our business and deliver services (e.g., debt collectors, IT suppliers, suppliers of procurement management services, communication platform providers) or our
  • professional advisors (e.g., law firms, insurers, auditors).
  • Government, regulatory and law enforcement bodies as required.

We may transfer your personal data from one supplier to another as part of service migration where we change providers for a particular service, for example, if we change our supplier of procurement management services. Less commonly, we may process and share your personal data with third parties where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent.

VIVO may share personal information with other companies within our shareholders’ group of companies located outside the European Economic Area, but we will take all reasonable steps to ensure such transfers are covered by our intra-group data sharing agreement entered into by relevant entities.

In the event that we do transfer your Personal data outside of the European Economic Area, we shall only do so in accordance with relevant Data Protection legislation.

Employee personal data will only be used for the purposes outlined above, and it may be shared within the shareholders’ group of companies (including any successors).

As outlined above, we may share your personal data with third parties working for us (for example pensions fund administrators), as well with other third parties (for example HMRC) where we are legally required to do so.

 

7. How long will you retain my Personal Data for?

As an employee, we will retain your data for as long as is necessary in order to achieve the purposes for which the Personal Data was obtained. In certain circumstances we may retain your personal data for longer e.g., final salary pension schemes.

 

8. Your legal rights

You have certain legal rights in relation to your personal information. For further details about these rights and how you may exercise them, or if you would like further information about the way we handle your Personal Data please contact [email protected].

We would be happy to address any concerns you have about your data privacy directly, and we encourage you to contact us in the first instance with your queries. However, you have a right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/ or telephone: 0303 123 1113) or other relevant supervisory authority who will then investigate your complaint accordingly.

 

9. Changes to this employee privacy notice

This employee privacy notice was updated in September 2023. We may amend this privacy notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check our website and/or intranet for the latest version of this privacy notice.