The Pioneer Group has responsibility under data protection legislation to provide individuals with information about how we collect and process their personal data. We do this in a number of ways, one of which is the publication of tailored privacy notices.

For details of our general approach to how we deal with your personal data, including an explanation of what rights you have in relation to us processing your personal data, how you can control how we use your information and how to inform us about your wishes please see our Privacy Statement.

This privacy notice applies to all current and former employees, workers, contractors, agency workers, directors, members and others working under the direction of the Pioneer Group (collectively “Company Personnel”), as well as any recruitment candidates who apply for a job with us.

This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time and will make an updated copy available on our website or intranet site. Where changes are significant, we will provide you with an updated copy of this notice as soon as reasonably practical.

What Data Will We Collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect personal information about Company Personnel and recruitment candidates through the application and recruitment process, either directly from
candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies. We have set out the different information we might collect at different stages of our relationship below, and the exact information collected will vary from individual to individual.

Pre-employment/Engagement Stage

We may collect certain recruitment information from you as an applicant for employment with us or engagement by us. This includes:

  • Personal contact details such as your name, address, contact telephone numbers (landline and mobile) and personal email addresses
  • Employment and education history including your qualifications, employment references
  • Proof of your identity
  • References and other information included in a CV or cover letter
  • CCTV images, where you attend our office for an interview.

Special Category Data

We may also process information about you that is more sensitive information and requires a higher level of protection. This special category data includes:

  • Health and wellbeing details, including disability status
  • Gender identification
  • Racial or ethnic origin
  • Religious beliefs
  • Right to work status/documentation and details of any criminal convictions that you declare
  • Other protected characteristics as defined by the Equality Act.

Employment/Engagement stage

The following categories will apply to all employees and workers.

Information Relating to Your Role with Us

We will use personal data provided by you to carry out the contract we have with you, provide you access to business services required for your role and manage our human resources processes.

  • Personal contact details such as your name, address, contact telephone numbers (landline and mobile) and personal email addresses
  • Your date of birth, gender and NI number
  • Marital status
  • Next of kin, emergency contacts and their contact information.
  • Employment and education history including your qualifications, job application, employment references, right to work information/documentation and details of any criminal convictions that you declare, together with any additional background checks relevant to the role
  • Location of employment
  • Details of any secondary employment, conflict of interest declarations or gift declarations
  • Any criminal convictions that you declare to us
  • Your responses to staff surveys if this data is not anonymised.

Information Relating to Your Salary/Payment and Pension

We process this information for payments to you, pension payments and other related benefits. We also process it for the administration of statutory and contractual leave entitlements such as holiday or maternity leave.

  • Information about your job role and your employment contract including: your start and leave dates; salary; and any changes to your employment contract working pattern (including any requests for flexible working)
  • Details of your time spent working and any overtime, expenses or other payments claimed
  • Details of any leave including sick leave, holidays, special leave etc
  • Pension details including membership of occupational pension schemes (current and previous)
  • Your bank account details, payroll records and tax and National Insurance status information
  • Details relating to Maternity, Paternity, Shared Parental and Adoption leave and pay. This includes forms applying for the relevant leave, copies of MATB1 forms/matching certificates and any other relevant documentation relating to the nature of the leave you will be taking.

Information Relating to Your Performance and Training

We use this information to assess your performance, to conduct pay reviews and to deal with any employer/employee related disputes. We also use it to meet the training and development needs required for your role.

  • Information relating to your performance at work e.g. probation reviews, performance reviews, promotions
  • Grievance and related investigations to which you may be a party or witness
  • Disciplinary records and documentation related to any investigations, hearings and warnings/penalties issued
  • Whistleblowing concerns raised by you, or to which you may be a party or witness
  • Information related to your training history and development needs.

Information relating to monitoring

  • We use this information to assess your compliance with corporate policies and procedures and to ensure the security of our premises, IT systems and Company Personnel
  • Information about your access to data held by us
  • Information derived from monitoring IT acceptable use standards
  • Photos and CCTV images
  • Security systems, including access card data.

Information Relating to Your Health and Wellbeing and Other Special Category Data

We use the following information to comply with our legal obligations and for equal opportunities monitoring. We also use it to ensure the health, safety and wellbeing of Company Personnel

  • Health and wellbeing information either declared by you or obtained from health checks, eye examinations, occupational health referrals and reports, sick leave forms, health questionnaires, return to work forms or fit notes i.e. Statement of Fitness for Work from your GP or hospital
  • Accident records if you have an accident at work
  • Details of any DSE assessment, access needs or reasonable adjustments.
  • Information you have provided regarding Protected Characteristics as defined by the Equality Act for the purpose of equal opportunities monitoring. This includes racial or ethnic origin, religious beliefs, disability status, and gender identification and may be extended to include other protected characteristics.

How will we collect your data?

Personal data will be collected from a number of sources throughout the application process and while you are working for us, including:

  • Directly from you
  • From employment agencies assisting us with recruitment
  • From systems we use to advertise or promote our vacancies, such as job boards, professional/social media platforms (like LinkedIn or other similar platforms) and our website
  • From providers of background checks and referees
  • From providers of occupational health services
  • From pensions administrators and government departments (for example tax details from HMRC)
  • From providers of staff benefits
  • By tracking your use of our IT and information services
  • From notes and records kept throughout your employment including absences, expenses claims, questionnaires, performance reviews and details of any grievances/disciplinary action
  • From CCTV and security/access card systems at our locations.

Lawful Grounds for Using Your Data

Where we process personal data, we have to identify appropriate lawful grounds for doing so. The main reasons we will use your personal data for is to perform the contract we have with you (or are entering into with you), where we need to comply with a legal obligation or where it is necessary for our legitimate business interests.

Where there is any special category data or criminal conviction data, we need to identify a second lawful ground to process this data, and this will be to carry out our obligations and exercise our rights in employment or to protect your vital interests. We may, in limited circumstances, use this information where it is necessary for the establishment, exercise or defence of legal claims or where you have made the information public yourself (for example through social media).

Where we collect data as part of an equal opportunities monitoring exercise, we are collecting this for the purpose of equality of opportunity or treatment, or to comply with legal obligations. We will minimise the data we collect through any such exercise and anonymise where possible.

Pre-employment/Engagement Stage

During the recruitment and application stage, your personal data will specifically be used:

  • To assess suitability, eligibility and/or fitness to work
  • To ensure our information and offices are secure
  • For management purposes (including where necessary for monitoring purposes)

Employment/Engagement Stage

Once you have completed the recruitment stage, your personal data will be used for:

  • Human resources or contract administration
  • Payroll and benefits administration
  • Assessing suitability, eligibility and/or fitness to work
  • Learning and development
  • To ensure our information and offices are secure
  • Management purposes (including where necessary disciplinary purposes).

In addition, photographs, education and career information may be used in our marketing and promotional material including our website, brochures, bids and tenders.

If You Fail to Provide Personal Information

If you fail to provide certain information when requested, we may not be able to enter into and/or perform the contract we have with you (such as where there is a question over your right to work or we need information to pay you or provide a benefit), or we may be prevented from complying with our legal obligations (like ensuring the health and safety of our Company Personnel).

Who will we share your data with?

Your personal data may be:

  • Transferred worldwide to our affiliates, and to service providers who support the operation of our business, such as recruitment agencies or our payroll bureau
  • Transferred to your referees to enable collection of references
  • Stored within our information systems and within third party software applications and services which have been procured to support the operation of our recruitment and HR function
  • Transferred to other third parties such as our insurers, legal and other professional advisors, auditors, regulators and administrators
  • Shared with government agencies (for example, we may share information about you with HMRC for the purpose of collecting tax and national insurance
    contributions)
  • Shared with our clients for the purposes of tendering for or providing services to clients
  • Shared where we are legally obliged to do so, such as under a court order.

When information is shared with third parties detailed above it will be limited to the minimum required to achieve the purpose it is being shared for and will be adequately protected.

How Long Will We Keep Your Data?

We will keep your personal data for as long as it is needed for the purpose for which it was originally collected. Under certain legislation and legal agreements, records containing the personal data may be required to be retained for set periods, for example in relation to certain Health and Safety legislation, insurance claims, where required under funded grants etc.

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
  • The applicable legal requirements.

Pre-employment/Engagement

We will normally keep your information throughout the process of recruiting for the role you have applied for, and for a period of up to 1 year once the role has been appointed or the vacancy cancelled. Where you are appointed into a role, your personal data will then be dealt with as Company Personnel.

Employment/Engagement

We will generally keep your information throughout the period of your employment with us, and we will keep major HR records for a period of 7 years after your employment ends. Major HR records include: wages/salary; payroll; PAYE; tax; written statements; training records; disciplinary and grievance records; job description; and equal opportunity related data.

We may keep information for a longer period where it relates to grant funding applications and claims that we have made. In such cases, the information will be retained for the period required under the relevant grant funding terms.

We will anonymise or minimise the personal data as much as we can, so we only retain the information required.