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Employee Privacy Notice

Introduction

To help us manage our relationship with you we may need to collect, store and use your personal information. From a legal point of view this is known as processing personal data.

Looking after your personal data is as important to us as it is to you and the information in this Privacy Notice will explain how and why we need to process your personal data, explain your rights and who you can contact to discuss the processing of your personal data.

You should read this Employee Privacy Notice prior to providing us with any personal data.

Who is this Privacy Notice from and who does it apply to?

This notice is being given by United Utilities Group PLC (the Group) and its subsidiaries which is a group of companies including United Utilities Water Limited, the water and wastewater undertaker for the North West of England.

The Group owns and operates a number of companies each of which look after and are separately responsible for your data (the Data Controllers). Which company or companies are relevant to you will depend on which part of the Group you work for. Most employees’ personal data will be controlled and processed by United Utilities Water Limited.

The following is a list of all the Data Controllers within the Group

  • United Utilities Utility Solutions Limited
  • United Utilities Utility Solutions (Industrial) Limited
  • United Utilities International Limited
  • United Utilities Pensions Trustee Limited
  • United Utilities PLC
  • United Utilities Property Services Limited
  • United Utilities Healthcare Trustee Limited
  • United Utilities Water Limited
  • UU (ESPS) Pensions Trustee Limited
  • United Utilities Total Solutions Limited
  • United Utilities Group PLC

All of the above companies have their registered offices at Haweswater House, Lingley Mere Business Park, Lingley Green Avenue, Great Sankey, Warrington, WA5 3LP.

This Notice is intended for all current, former, prospective, permanent,  and temporary employees of the Group as well as current, permanent and temporary employees of any 3rd party to the extent that they are contracted to carry out work on United Utilities' behalf.

Any reference to “we” or “us” in this notice means any one of the above listed Data Controllers within the Group as relevant to the circumstances. Any reference to “employee” includes current permanent and temporary employee of the Group.

Please note that we may use a number of external third parties who might process your personal data on our behalf, these companies are referred to as ‘Data Processors’. Any Data Processors we use also have their own legal responsibility for handling your data. Full details of these can be obtained by contacting us (see “Who can I contact about my personal data” section below).

What information does United Utilities collect about its employees?

From time to time, depending on the circumstances, we may collect and process a range of information about you. This includes:

  • Your name, address and contact details, including email addresses and telephone numbers, date of birth and gender
  • The terms and conditions of your employment
  • Details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and within United Utilities
  • Information about your remuneration, expenses (where relevant details about the type of car you drive), including entitlement to benefits such as pensions or insurance cover
  • Details of your bank account and National Insurance number
  • Information about your marital status, next of kin, dependants and emergency contacts
  • Information about your nationality and entitlement to work in the UK
  • Details of your schedule (days of work and working hours) and attendance at work
  • Details of periods of leave taken by you, including but not limited to holiday, sickness absence, family leave and sabbaticals, and the reasons for the leave
  • Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence
  • Assessments of your performance, including appraisals, performance reviews and ratings, performance improvement plans and related correspondence Information about medical or health conditions, including whether or not you have a disability for which we need to make reasonable adjustments
  • Equal opportunities monitoring information including information about your ethnic origin, sexual orientation and religion or belief
  • Monitoring of UU vehicles by telematics and vehicle cameras
  • CCTV images of you, your vehicle registration number and your personal vehicles on United Utilities sites
  • Monitoring of company computers (including laptops), mobile, smartphone or tablet device, social media, email and internet use whether on site or working remotely
  • Criminal records data meaning information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings
  • Personal data relating to any company share planse

We may collect this information in a variety of ways. For example, data might be collected through application forms, CVs or resumes, obtained from your passport or other identity documents such as your driving licence, from forms completed by you at the start of or during employment (such as benefit nomination forms), from correspondence with you or through interviews, meetings, CCTV or other assessments.

In some cases, we may collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers, information from credit reference agencies, driver licence details from DVLA and information from criminal records checks permitted by law.

Where the data we process is classed as special category personal data, (sometimes known as sensitive personal data), or relates to criminal conviction or offences this is done in accordance with our policy on special categories of data and criminal records data.

We will update HR-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.

Personal data gathered during the employment, worker, contractor or volunteer relationship, or apprenticeship or internship is held in the individual's personnel file in hard copy or electronic format, or both, and on HR management systems.

We keep a record of our processing activities in respect of HR-related personal data in accordance with the requirements of UK data protection law. We will always attempt to seek your consent if required prior to obtaining your personal information from a third party.

Data will be stored in a range of different places, including in your personnel file, in our HR management systems and in other IT systems (including the email system).

Why do we process your data?

We need to process your personal data to enter into an employment contract with you and to meet the obligations of your employment contract including pay, pensions, share schemes and other benefits.

We also need to process your personal data to ensure that we comply with our legal obligations. For example, we are required to check an employee's entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled. Criminal convictions and offence data (including information relating to criminal allegations and proceedings) are also processed to prevent and detect unlawful acts, protect the public from dishonesty and prevent fraud.

In other cases, we have a legitimate interest in processing your personal data before commencement of, during and after the end of the employment relationship. Processing employee data allows us to:

  • Run recruitment and selection processes
  • Maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency) and records of employee contractual and statutory rights
  • Operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace
  • Operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes
  • Operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled
  • Obtain occupational health advice, to ensure that we comply with our duties in relation to individuals with disabilities, meet our obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled 
  • Operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that we comply with our duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled
  • Ensure effective general HR and business administration including expenses
  • Provide references on request for current or former employees
  • Respond to and defend against legal claims
  • Enure the health, safety and security of our employees
  • To deliver and provide Training and Education

Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (such as those in relation to employees with disabilities).

Where we process other special categories of personal data, such as information about ethnic origin, sexual orientation or religion or belief, this is done for the purposes of equal opportunities monitoring. This is to carry out our obligations and exercise specific rights in relation to employment. Employees are entirely free to decide whether or not to provide such data and there are no consequences for not doing so.

Who has access to your data?

Your personal data may be shared internally, including with members of the HR and recruitment team (including payroll), your line manager, managers in the business area in which you work and IT staff if access to the data is necessary for performance of their roles.

We may share your data with third parties in order to obtain or provide pre-employment references from other employers, obtain employment background checks from third-party providers and obtain necessary criminal records checks from the Disclosure and Barring Service. We may also share your data with third parties in the context of a sale of some or all of our business. In those circumstances the data will be subject to confidentiality arrangements. 

We also share your data with third parties that process data on our behalf, in connection with payroll, the provision of benefits and the provision of occupational health services and HR advice guidance.

Your data may be transferred to other countries where we are working with contractors, for example to undertake testing or develop new computer systems. Where data is transferred we will ensure there are adequate security and contractual measures in place. 

We will provide training to all individuals about their data protection responsibilities as part of the induction process and depending upon role at regular intervals thereafter. Individuals whose roles require regular access to personal data, or who are responsible for implementing this Privacy Notice or responding to subject access requests under this Privacy Notice, will receive additional training to help them understand their duties and how to comply with them.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the disciplinary policy. Significant or deliberate breaches of this Privacy Notice, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

How do we protect your data?

We take the security of HR-related personal data seriously. The organisation has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. More detail can be found in the Security Policy Framework. 

Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

How long do we keep your data for?

We will hold your personal data for the duration of your employment. The periods for which your data is held after the end of employment are set out in the retention period document available in the Internal Control Manual on the ONE Intranet site. 

Any external providers would have their own retention period. You can find out these in accordance with your Data Protection rights below.

Your Data Protection Rights

In accordance with current UK data protection law you have a number of rights relating to the processing of your personal data. These rights include:

  • Right of Access – this right entitles you to request a copy of any of the information we hold about you
  • Right to be Informed – this right entitles you to request to be provided with details of how we process your personal data. This is the purpose of this Privacy Notice
  • Right to Rectification – this right entitles you to request the correction of any personal data you believe is inaccurate or incomplete
  • Right of Erasure - this right entitles you to request the deletion or removal of personal data where there is no reason for its continued processing. This right is also known as the “Right to be Forgotten”
  • Right to Restrict Processing – this right entitles you to request no further processing of the personal data we have previously collected
  • Right to Object – this right entitles you to request that your personal data is not processed for specific purposes such as marketing or to challenge the basis of processing your data
  • Right to data portability – you have a right to ask for any personal data we hold on you electronically to be sent to another Data Controller of your choice 
  • Right to withdraw consent – where we have obtained your data with your consent, for example when you start your job with us, you have the right to withdraw that consent at any time. However this will not have affected our legal ability to do this before you withdraw your consent

To exercise your right please see the “Who can I contact about my personal data” section below.

Please be aware there may be circumstances when we are unable to complete your request to exercise your rights. If this is ever the case we will inform you of the reason and provide details of how you can register a complaint with the Information Commissioner’s Office.

What if you do not provide personal data?

You have certain obligations under your employment contract to provide us with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide us with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.

Certain information, such as contact details, your right to work in the UK and payment details, have to be provided to enable us to enter into a contract of employment with you. If you do not provide information, this will hinder our ability to administer the rights and obligations arising as a result of the employment relationship. 

Automated decision-making

Employment decisions are not based solely on automated decision-making. However we may make decisions in an automated way to assess your eligibility or suitability to receive or be informed about certain offers or other company benefits, such as vouchers and share schemes.

Changes to this Privacy Notice

We continually review and update this Privacy Notice to reflect changes in our services as well as to comply with changes in Data Protection Laws and Legislation so would encourage you to review this on a regular basis.

Who can I contact about my personal data?

Should you need to contact us to discuss the handling of your personal data or to submit a request to exercise one of your Data Protection Rights, or to receive more detail about what specific data we process, who receives it, how long we keep it, please contact our Data Protection Team using one of the following methods:

Post: United Utilities, Legal Department, Grasmere House, Lingley Mere Business Park, Lingley Green Avenue, Warrington, WA5 3LP

Email: DataProtectionandFraud@uuplc.co.uk

Telephone: 0345 075 0715 and ask to be put through to the Data Protection Team in the Legal Department

How can I contact the Information Commissioner’s Office?

Whilst we hope that we can address any questions or concerns, should you need to contact the Information Commissioner’s Office you can do so using one of the following methods:

Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113 or 01625 545 745

Website: https://ico.org.uk