At The Barnet Group, we’re committed to protecting and respecting your privacy.
The Barnet Group does not process any personal data. All subsidiaries of the Group are registered with the Information Commissioner’s Office and are data controllers and/or data processors.
Customers can read the privacy policies on each subsidiary’s website:
We may change this policy from time to time to reflect changes to legislation and ways of working. We recommend checking this page occasionally to ensure that you’re happy with any changes.
Any questions regarding this policy and our privacy practices should be sent by email to Talk2Us@barnethomes.org, or by writing to The Barnet Group, 3rd Floor, 2 Bristol Avenue, London, NW9 4EW. Alternatively, you can telephone 020 8080 6587.
Our Data Protection Officer is Denise Ailara, Data Protection and Compliance Officer.
Who are we?
TBG Flex is a company for the recruitment and employment of staff which is incorporated in England (09842642). The registered address is 3rd Floor, 2 Bristol Avenue, London, NW9 4EW.
Barnet Homes is an Arms-Length Management Organisation (ALMO) which is wholly owned by the London Borough of Barnet and is incorporated in England (04948659). The registered address is 3rd Floor, 2 Bristol Avenue, London, NW9 4EW.
Your Choice (Barnet) is a provider of adult social care services which is incorporated in England (07873969). The registered address is 3rd Floor, 2 Bristol Avenue, London, NW9 4EW.
They are all members of The Barnet Group Limited. The Barnet Group includes Barnet Homes, Your Choice (Barnet) Limited, TBG Open Door Limited (‘Opendoor Homes’), Bumblebee Lettings Limited, and TBG Flex Limited.
How do we collect information from you?
We will only collect personal information when we need this. Personal information means information which can identify you as an individual. When we ask you for information we will make it clear why we need it. We will also make it clear when you do not have to provide us with information, and any consequences of not providing this.
Most information we hold will be collected from you, and you will usually provide this information directly to your manager or HR contact, or enter it onto our systems, for example through iTrent, your participation in HR processes, emails, and instant messages. In addition, further information about you will come from your managers, HR or occasionally from your colleagues.
We may also obtain information from third parties such as references from a previous employer, medical reports from external professionals, and information from tax authorities, benefit providers, or where we employ a third party to carry out a background check (where authorised by applicable law).
In some circumstances, personal information may be collected indirectly from monitoring devices or by other means (for example, building and location access control and monitoring systems, CCTV, telephone logs and recordings, and email and Internet access logs), if and to the extent authorised by applicable laws.
Where we ask you to provide personal information to us on a mandatory basis, we will inform you of this at the time of collection and in the event that particular information is required by the contract or statute this will be indicated. The failure to provide mandatory information will mean that we cannot carry out certain HR processes. For example, if you do not provide us with your bank details, we will not be able to pay you.
Apart from personal information relating to you, you may also provide us with personal information of third parties, notably your dependants and other family members, for purposes of HR administration and management, including the administration of benefits and someone to contact in an emergency. Before you provide such third party personal information to us you must first inform these third parties of any such information that you intend to provide and of the processing to be carried out by The Barnet Group, as detailed in this notice.
We may take photographs at events organised and hosted by The Barnet Group. The images may be used on our websites, in brochures, and in other publicity materials such as newsletters, and may be provided to the media for publication in local or national newspapers or magazines. You will always be given the option not to be included in photographs.
What type of information is collected from you?
We may collect the following personal information about you for the purposes described in this notice:
- Personal details: your title, name, previous or maiden name, gender, nationality, civil/marital status, date of birth, age, personal contact details, national ID number, eligibility to work information, passport, driving licence, languages spoken, emergency contact information, and details of any disability and any reasonable adjustments required as a result.
- Recruitment and selection information: skills and experience, qualifications, references, CV and application, interview and assessment data, background and verification information related to the outcome of your application, and details of any offer made to you.
- Information related to your engagement: contract of employment or engagement, work contact details, employee or payroll number, photograph, work location, your worker ID and various system IDs, your work biography, your assigned business unit or group, your reporting line, your employee/contingent worker type, your termination/contract end date, the reason for termination, your last day of work, and exit interviews.
- Regulatory information: records of your registration with any applicable regulatory authority, your regulated status, including any criminal record or credit background checks which may be necessary, and any regulatory certificates and references.
- Remuneration and benefits information: your remuneration information (including salary/contract pay/fees information as applicable, allowances, overtime, bonus plans), payments for leave, bank account details, grade, tax information, details of any benefits you receive or are eligible for, benefit coverage start date, expense claims and payments, and information and agreements.
- Leave and absence management information: attendance records, absence records, holiday dates, requests and approvals and information related to family leave or other special or statutory leave, absence history, fit notes, details of incapacity, details of work impact and adjustments, manager and Human Resources (HR) communications, and return to work interviews.
- Performance management information: colleague and manager feedback, your appraisals and performance review information, outcomes and objectives, talent programme assessments and records, succession plans, and formal and informal performance management process records.
- Training and development information: data relating to training and development needs or training received or assessments completed.
- Monitoring information (to the extent authorised by applicable laws): closed circuit television footage, system and building log-in and access records, photo on access card, download and print records, call or meeting recordings, and information captured by IT security programmes and filters.
- Employee claims, complaints, and disclosures information: subject matter of employment or contract based litigation and complaints, pre-claim conciliation, communications, settlement discussions, claim proceeding records, employee involvement in incident reporting and disclosures.
- Equality and diversity information (where authorised by law and consent provided voluntarily): information regarding gender, age, nationality, religious belief, sexuality and race.
How is your information used?
Subject to applicable law, your personal data may be stored and processed by us for the following purposes:
Recruitment and selection
- To evaluate applications for employment and make decisions in relation to selection of employees;
- Pre-employment screening including, where relevant and appropriate, identity check, right to work verification, reference check, credit check, financial sanction check, and criminal record checks;
- To make job offers, providing contracts of employment or engagement and preparing to commence your employment or engagement where you accept an offer from us;
- To contact you should another potentially suitable vacancy arise;
- To deal with any query, challenge, or request for feedback received in relation to our recruitment decisions; and
- To monitor programmes to ensure equality of opportunity and diversity.
Ongoing management of all aspects of employees’ relationships with The Barnet Group
- To manage and maintain HR hard copy records, files and systems, including technical support and maintenance of HR systems and managing electronic and hard copy records in line with The Barnet Group’s records retention schedules;
- Providing and administering remuneration, benefits, pensions, and incentive schemes;
- To make appropriate tax and national insurance deductions and contributions;
- To set and change building and system access permissions;
- Identifying and communicating effectively with employees;
- Where appropriate, publishing appropriate internal or external communications or publicity material, including via social media;
- Managing and operating performance reviews, capability, attendance, and talent programmes;
- Managing grievances, allegations (e.g. whistleblowing, harassment), complaints, investigations and disciplinary processes, and making related management decisions;
- Training, development, promotion, career and succession planning, and business contingency planning; and
- Processing details with employee consent of membership of trade unions, and other employee representative bodies and to administer any associated subscriptions paid direct from salaries.
Absence management and health and safety
- Processing information about absence;
- Processing medical information regarding physical or mental health or condition to assess eligibility for incapacity or permanent disability related remuneration or benefits:
- determine fitness for work;
- facilitate a return to work;
- make adjustments or accommodations to duties or the workplace;
- make management decisions regarding employment or engagement or continued employment or engagement or redeployment; and/or
- conduct-related management processes.
Compliance monitoring, security and systems use
- Measuring the performance of The Barnet Group’s IT systems by monitoring employee usage of systems; this includes analysing times, locations, and activities whilst users are logged into the network;
- Auditing, monitoring, investigation, and compliance monitoring activities in relation to The Barnet Group policies, Code of Conduct, applicable law, the prevention and detection of criminal activity, and to protect The Barnet Group’s and the London Borough of Barnet’s assets and premises.
Responding to legal and regulatory requests
- Comply with lawful requests by public authorities, disclosure requests, or where otherwise required or authorised by applicable laws, court orders, government regulations, or regulatory authorities (including without limitation data protection, tax and employment);
- Termination of employment and managing post-employment relationships;
- Complying with reference requests where The Barnet Group or one of its subsidiaries is named by the individual as a referee;
- Administering termination and post-termination matters, e.g. outplacement services, liaison with employee legal representatives, enforcing restrictive covenants, loan repayments, overpayments, expense reimbursements, employee benefits, conduct termination, and post-termination litigation.
To the extent authorised by local laws, The Barnet Group may collect and process a limited amount of personal information falling into special categories, sometimes called ‘sensitive personal information’. This term means information relating to:
- health-related details, including any special dietary requirements and any reasonable adjustments that the company may be required by law to make to your working arrangements;
- information revealing racial or ethnic origin;
- judicial information, including the results of criminal or police records checks which can include details of offences, alleged offences and sentences, and information from other intelligence sources (subject to relevant local laws and record retention periods);
- marital status and next of kin; and
- political opinions or contributions, religious beliefs or other similar beliefs, and sexual orientation, should you choose to provide any such information.
We will only collect, use and share your personal information where we are satisfied that one or more of the following legal bases apply:
- The processing is necessary for compliance with a legal obligation to which The Barnet Group is subject, for example, disclosing information to local tax authorities, making statutory payments, avoiding unlawful termination, avoiding unlawful discrimination, meeting statutory record keeping requirements, or health and safety obligations;
- The processing is necessary for the performance of a contract to which you are a party or in order to take steps, at your request, prior to entering into such a contract, for example collecting bank details to pay your salary or processing information to provide you with the contractual benefits to which you are entitled;
- The processing is based on your consent. Where consent is required for the processing in question, it will be sought from you separately to ensure that it is freely given, informed and explicit. Information regarding such processing will be provided to you at the time that consent is requested, along with the impact of not providing any such consent. You should be aware that it is not a condition or requirement of your employment to agree to any request for consent from The Barnet Group; and/or
- The processing is necessary for the legitimate interests pursued by The Barnet Group or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information. The Barnet Group considers that it has a legitimate interest in processing personal information for the purposes set out above, and to support the achievement of its immediate and long-term business goals and outcomes.
Who has access to your information?
For the above purposes, personal information may be transferred within or outside of the jurisdiction where you are employed or perform work, either within The Barnet Group or to third parties, including, but not limited to:
- any holding company, subsidiary, affiliate of The Barnet Group; and/or
- certain third party including suppliers and service providers including; payroll, pension providers to whom The Barnet Group may disclose personal information when required by law or court order, or as requested by any government or regulator or law enforcement authority or agency.
The Barnet Group may also disclose personal information to a third party where it is necessary to do so in order to protect or pursue The Barnet Group’s legitimate interests (ensuring this is proportionate and limited to that information which is strictly necessary in the circumstances). This may include, but not be limited to, disclosure to a party with whom The Barnet Group is in negotiation for the sale or transfer of a business, assets, or services. The Barnet Group will take appropriate steps to ensure that the recipient of personal information in such circumstances puts in place an adequate level of protection for such personal information in accordance with applicable legal requirements.
Your rights, and how you can access and update your information
We are committed to upholding your rights in respect of your personal data.
The right to be informed
Through the provision of our suite of privacy notices, we will be open and transparent about how and why we use your personal information.
The right of access
You have the right to request a copy of the personal information we hold about you. This is known as a Subject Access request. In order for us to process a Subject Access Request we need this to be made in writing (we have a Subject Access Request form you can use for this purpose, to make it easier to include all the details we might need to locate the information you want), and we ask that your written request is accompanied by proof of your identity and address.
If someone is requesting information on your behalf, they will need written confirmation from you to evidence your consent for us to release this and proof of ID (both yours and theirs).
If you are seeking to obtain specific information (for example, about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your written request.
Once your request has been received, along with your proof of identity and address, we will provide your information within one month.
In response to Subject Access Requests we will provide you with a copy of the information we hold that relates to you.
The right to rectification
You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.
The right to erasure
The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our Records Retention Schedule.
The right to restrict processing
In some circumstances you can ask us to restrict processing, for example
- If you disagree with the accuracy of personal data.
- If we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds override those of yours.
We will assess your request and seek to comply with it; however, there will be some situations where we will be unable to comply – for example due to a legal requirement or where processing of personal information is necessary in relation to providing a service. Where this is the case we will inform you of the reason for this.
The right to data portability
If the situation arises where it would be helpful for you to move, copy, or transfer personal data we hold about you, across different services, you may be able to ask us to do this. Please contact us to discuss.
The right to object
You can tell us if you object to our processing of your personal data:
- Based on legitimate interests.
- For the purpose of direct marketing (including profiling);
If you’d like to talk to us about your rights, you can contact us at Talk2Us@barnethomes.org or speak directly to the HR team.
Further information on raising data protection concerns can be found on the Information Commissioner’s Website or you can contact the ICO to seek an independent view
Security precautions in place to protect the loss, misuse, or alteration of your information
We take our responsibilities to under data protection legislation very seriously, and we will apply appropriate technical and organisational measures to ensure your personal information is secure. For example, we have a number of policies, procedures, and templates in place in relation to protecting personal data, in addition to systems to ensure that access to personal information is restricted to authorised individuals on a strictly need-to-know basis. We also ensure all employees complete new starter training and annual refresher training on data protection.
When we need to share personal data with third party suppliers, our relationships are governed by our contracts with them which include strict data sharing and confidentiality protocols.
We only hold records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us. We have a Records Retention Schedule which sets out how long we keep different types of information for. We review our retention periods for personal information on a regular basis.
Links to other websites
Our website may contain links to other websites run by other organisations. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. When you are transferred to another site by following an external link we recommend that you read their privacy statement on their use of your personal data.