Employee Privacy Notice

Syncona Investment Management Limited (‘SIML’ or ‘we’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and law.

This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data.

SIML 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 and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services.

Note that a separate privacy notice applies to our website and will apply if you use our website.

Data protection principles

We will comply with data protection law. This states 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.

Information that we collect

We will collect the following categories of personal data from you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  • Date of birth
  • National Insurance number
  • Bank Account details, payroll records and tax status information.
  • Gender
  • Marital status and dependants
  • Next of kin and emergency contact information
  • Copy of driving licence or passport
  • Recruitment information (including copies of right to work documentation, CVs, references and other information required as part of the application process.
  • Employment records (including job titles, work history, working hours, compensation history training records and professional memberships)
  • Salary, annual leave, pension and benefits information
  • Performance information
  • Disciplinary and grievance information
  • Information about your use of our information and communications systems
  • CCTV footage and other information obtained through electronic means such as swipecard records

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

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
  • Information about your health, including any medical condition, health and sickness records;
  • Genetic information and biometric data; and
  • 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, directly from candidates or through our outsourced HR service provider, Apodi Limited, or sometimes from an employment agency. We may also collect additional information from third parties including former employers, credit reference agencies or other background check agencies.

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

When will we use 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 (which are permitted by law):

  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 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:

  1. Where we need to protect your interests (or someone else's interests).
  2. Where it is needed in the public interest.

Situations in which we will use 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 tax and National Insurance contributions;
  • Liaising with your pension provider;
  • In order to provide health insurance cover;
  • Administering the contract we have entered into with you;
  • Business management and planning, including accounting and auditing;
  • Organising your business travel arrangements;
  • Providing information as required for us to comply with “know your client” requirements;
  • 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, or other employees, workers and contractors, including accidents at work;
  • Ascertaining your fitness to work;
  • Managing sickness absence;
  • Complying with health and safety obligations;
  • Preventing fraud;
  • Monitoring your use of our information and communication systems to ensure compliance with our IT policies;
  • Ensuring network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution; and
  • 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.

If we collected your personal information for a particular purpose then we will only use it for that purpose, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

How “special category” sensitive information is used

"Special categories" of particularly sensitive personal information require higher levels of protection. For example, relating to an individual’s race, ethnic origin, politics, religion, health or sexual orientation.

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

  • In limited circumstances, with your explicit written consent;
  • Where we need to carry out our legal obligations or exercise rights in relation to your employment with us, in which case your consent is not required.
  • We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data; or
  • Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our corporate pension scheme. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Situations in which we will use your particularly sensitive personal information are listed below:

  • 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.
  • We may use relevant information to ensure meaningful equal opportunity monitoring and reporting.

We do not need your consent to use this 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 consent to allow us to take particular steps. 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.

Data sharing

We may share your data with third parties as necessary to administer the working relationship with you or where we have another legitimate interest in doing so. We require third parties to respect the security of your data and to treat it in accordance with the law.

Examples of third parties would include the following:

  • Our outsourced HR service provider (Apodi Limited);
  • Affiliated entities and group companies;
  • Payroll administration;
  • Pension administration;
  • Health insurance and other benefits providers, or benefits administrators (TEBC Limited).

The above list is not exhaustive and may be subject to change.

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 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. Further details can be found in the Data Protection Policy.

Retention Periods

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. 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. 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.

Further details can be found in the Data Protection Policy.

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).

Similarly, 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 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. Requests can be made to our Compliance Officer.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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 Compliance Officer in writing.

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. We will aim to comply with your request within a 30-day timeframe.

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 Compliance 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.

Changes to this privacy policy

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.

Lodging a complaint

SIML only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK authority for data protection issues.