A) Data Protection Principals

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

  1. Processing is fair, lawful and transparent
  2. Data is collected for specific, explicit, and legitimate purposes
  3. Data collected is adequate, relevant and limited to what is necessary for the purposes of processing
  4. Data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without
  5. Data is not kept for longer than is necessary for its given purpose
  6. Data is processed in a manner that ensures appropriate security of personal data including protection against
    unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or
    organisation measures
  7. We comply with the relevant GDPR procedures for international transferring of personal data

B) Types of Data Held

We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each employee and we also hold the data within our computer systems, for example, our holiday booking system. Specifically, we hold the following types of data:

  1. Personal details such as name, address, phone numbers, email addresses
  2. Name and contact details of your next of kin
  3. Your photograph
  4. Your gender, marital status,information of any disability you have or other medical information
  5. Right to work documentation
  6. Information on your race and religion for equality monitoring purposes
  7. Information gathered via the recruitment process such as that entered into a CV/application form or included in
    a cover letter
  8. References from former employers
  9. Details on your education and employment history etc
  10. National Insurance numbers
  11. Bank account details
  12. Tax codes
  13. Driving licence and other relevant driving documentation
  14. Criminal convictions and DBS information
  15. Information relating to your employment with us, including:
    1. job title and job descriptions
    2. your salary
    3. your wider terms and conditions of employment
    4. details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information
  16. CCTV footage
  17. Attendance records
  18. IT equipment use including telephones and internet access.

C) Collecting your Data

You provide several pieces of data to us directly during the recruitment exercise.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references.

Personal data is kept in files or within the Company’s HR and IT systems.

D) Lawful Basis for Processing

The law on data protection allows us to process your data for certain reasons only. In the main, we process your data in order to comply with a legal requirement or in order to effectively manage the employment contract we have with you, including ensuring you are paid correctly.

The information below categorises the types of data processing we undertake and the lawful basis we rely on:

Activity requiring your data Lawful basis
Carry out the employment contract that we have entered into  with you e.g. using  your name, contact details, education history, information on any disciplinary, grievance procedures involving you Performance of the contract
Ensuring you are paid Performance of the contract
Ensuring tax and National Insurance is paid Legal obligation
Carrying out checks in relation to your right to work in the UK Legal obligation
Making reasonable adjustments for disabled employees Legal obligation
Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion Our legitimate interests
Making decisions about salary and other benefits Our legitimate interests
Ensuring efficient administration of contractual benefits to you Our legitimate interests
Effectively monitoring both your conduct, including timekeeping and attendance, and your performance and to undertake procedures where necessary Our legitimate interests
Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained Our legitimate interests
Implementing grievance procedures Our legitimate interests
Assessing training needs Our legitimate interests
Implementing an effective sickness absence management system including monitoring the amount of leave and subsequent actions to be taken including the making of reasonable adjustments Our legitimate interests
Gaining expert medical opinion when making decisions about your fitness for work Our legitimate interests
Managing statutory leave and pay systems such as maternity leave and pay etc Our legitimate interests
Business planning and restructuring exercises Our legitimate interests
Dealing with legal claims made against us Our legitimate interests
Preventing fraud Our legitimate interests
Ensuring our administrative and IT systems are secure and robust against unauthorised access Our legitimate interests
DBS (Disclosure and Barring Service) Legal Obligation

E) Special Categories of Data

Special categories of data are data relating to your:

  1. Health
  2. Criminal Convictions
  3. Sexual orientation
  4. Race
  5. Ethnic origin
  6. Religious belief.

We process your special category data because:

  • It is necessary due to the health & social care act 2008 (schedule 3) as we are required to perform Disclosure and Barring Service (DBS) checks on our staff
  • It is necessary for us to process requests for sick pay or maternity pay
  • We are required to provide data to our regulator, the Care Quality Commission (CQC), as part of our public interest obligations

We carry out processing activities using special category data:

  1. For the purposes of equal opportunities monitoring
  2. In our sickness absence management procedures
  3. To determine reasonable adjustments

Most commonly, we will process special categories of data when the following

  1. You have given explicit consent to the processing
  2. We must process the data in order to carry out our legal obligations
  3. We must process data for reasons of substantial public interest
  4. You have already made the data public.

F) Failure to Provide Data

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment or administer contractual benefits.

In addition,  it may also result in dismissal if some certain criteria is not met under our legal obligation.

G) Criminal Conviction Data

We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment  stage and  will  also be collected during your employment. We use the DBS  service to obtain relevant disclosures and we use these disclosures and criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of the health & social care act 2008 (schedule 3) to process this data.

H) Who we Share your Data With

Employees within our company who have responsibility for recruitment, administration of payment and contractual benefits and the carrying out of performance related procedures will have access to your data which is relevant to their function. Data is shared with third parties for the following reasons:

  • Her Majesty’s Revenue and Customs (HMRC)
  • Pension and Healthcare Schemes (People’s pension, Scottish Widows)
  • Our Insurance (Bollingtons)
  • Local Authorities (West Yorkshire, North Yorkshire, South Yorkshire, East Yorkshire)
  • Organisations we have a legal obligation to share information with i.e. for Safeguarding, CQC, DBS
  • The police or other law enforcement agencies or court orders
  • Banks and Building Societies, where financial / personal data is requested for processing your mortgage or loan application
  • Letting Agencies, for processing your application to let properties
  • Other Employers, seeking references for you

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

We do not share your data with bodies outside of the European Economic Area.

I) Protecting your Data

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We are continuing to implement processes and new computer systems to guard against such matters.

J) Retention Periods

We only keep your data for as long as we need it for, which will be at least for the duration of your employment with us though in some cases we will keep your data for a period after your employment has ended. Some data retention periods are set by the law. Retention periods can vary depending on why we need your data, as set out below:

Record Millennium / Statutory Retention Period 
Retirement Benefits Schemes 6 years from the end of the scheme year
Statutory Maternity Pay (calculations, certificates, medical evidence) 6 years after the end on the tax year in which the period ends
Wage/salary (overtime, bonuses, expenses) 6 years
National Minimum Wage 6 years after the end of the consequent pay reference period
Time sheets / Clocking in Systems 6 years
Assessments under health and safety regulations and records of consultations with safety representatives and committees Permanently
HMRC approvals Permanently
Expenses and receipts 6 years
Pension scheme investment policies 12 years from the ending of any benefit payable under the policy
Personnel files, including recruitment, internal promotions, training records, disciplinary records,
working time records, absence records etc
6 years after end of employment
Redundancy details, calculations of payments, refunds, notification to HMRC 6 years after date of redundancy
Statutory Sick Pay records, calculations, certificates, self-certificates 6 years after the employment ceases
Criminal Records or DBS 6 years in line with Personnel files

K) Automated Decision Making

Automated decision-making means making decision about you using no human involvement e.g. using computerised filtering equipment. Millennium Care does not undertake such processes.

L) Your Rights

You have the following rights in relation to the personal data we hold on you:

  1. The right to be informed about the data we hold on you and what we do with it;
  2. The right of access to the data we hold on you.
  3. The right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  4. The right to have data deleted in certain circumstances. This is also known as ‘erasure’;
  5. The right to restrict the processing of the data;
  6. The right to transfer the data we hold on you to another party. This is also known as ‘portability’;
  7. The right to object to the inclusion of any information;
  8. The right to regulate any automated decision-making and profiling of personal data.

M) Consent

Where the lawful basis for processing your data is via you having given Millennium Care your consent, you have the right to withdraw your consent at any time by request.

Should you wish to contact us, please ask for the “data protection lead” via the following options:

N) Data Protection Lead at Millennium Support

Should you wish to contact us, please ask for the “data protection lead” via the following options:

Telephone: 01977 602867
Email address: [email protected]
Address: Millennium Care Services
Ltd, Station Lane,
West Yorkshire

N) Making a Complaint to the Information Commissioner’s Office (ICO)

If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at:

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

0303 123 1113
(local rate) or
01625 545 745