Employee Privacy Notice

We, Language Empire Ltd, are committed to protecting your privacy.  We collect, store, and use information about individuals securely and respectfully, in full compliance with applicable legislation, including the United Kingdom General Data Protection Regulation (UK GDPR), Data Protection Act 2018 (DPA 2018) and Electronic Communications (EC Directive) Regulations 2004.
Language Empire is a “data controller”.  This means that we are responsible for deciding how we hold and use your personal information.  We collect, store and process personal data relating to our employees to manage the employment relationship. This privacy notice sets down how we collect and use personal information about you during and after your working relationship with us.
This notice does not form part of a contract of employment or any contract to provide services and may be updated at any time.

1.    Who does this apply to

This privacy notice applies to current and former employees, workers, freelancers and contractors.

2.    Information we collect about you

Language Empire collects and processes a range of personal information (personal data) about you. Personal data means any information about an individual from which the person can be identified. This includes:

• Personal contact details, such as your name, title, address and contact details, including email address and telephone number;
• date of birth;
• gender;
• the terms and conditions of your employment;
• Interview information, including interview notes, assessment results and performance in role-play scenarios
• details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with the Company;
• information about your remuneration, including entitlement to benefits such as pensions;
• details of your bank account, tax status 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;
• copy of driving licence;

• details of periods of leave taken by you, including 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, training you have participated in, performance improvement plans and related correspondence;
• CCTV footage and other information obtained through electronic means e.g. swipe card records.

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

• information about medical or health conditions, including whether or not you have a disability for which we need to make reasonable adjustments;
• details of trade union membership; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief].

Data is stored in a range of different places, including in your personnel file, in the Company’s HR systems and other IT systems (including the Language Empire’s email system).

3.    Situations In Which We Will Use Your Personal Information

Situations in which we will process your personal information are listed below:

• To make decisions about recruitment and promotion processes;
• To maintain accurate and up-to-date employment records and contact details (including details of whom to contact in the event of an emergency), and records of employee contractual and statutory rights;
• To check you are legally entitled to work in the UK;
• To gather evidence for, and keep a record of, disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
• To pay you and, in the case of employees, make deductions for tax and National Insurance;
• To make decisions about salary reviews and compensation;
• To operate and keep a record of employee performance and related processes;
• To keep records of training and development requirements;
• To 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;
• To ascertain your fitness to work;
• To operate and keep a record of other types of leave (such as maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that the organisation complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled;
• To ensure effective general HR and business administration;
• To provide references on request for current or former employees;
• To deal with legal disputes involving you or other employees, workers and contractors; and
• To facilitate equal opportunities monitoring in the workplace.

4.    The methods we use to collect information about you

We collect information electronically (or in hard copy) in a variety of ways, including:

• Pre-employment and Onboarding:  Job applications and resumes, Background checks and references, Onboarding paperwork (e.g. LE New Employee Forms and HMRC P46) and Emergency contact information
• Performance and Productivity:  Performance reviews and evaluations, Time tracking and attendance systems, Project management and task tracking tools and Customer feedback related to employee performance
• Compensation and Benefits:  Payroll and compensation records, Benefits enrolment forms and Expense reports and reimbursement requests
• Professional Development:  Training and development records and Professional certifications and licenses
• Communication and Technology Use:  Work emails and communications and Computer and network usage logs
• Physical Security and Access:  Security camera footage (in office spaces), Badge access logs for building entry/exit and Biometric data (e.g., fingerprints for time clocks)
• Health and Safety:  Medical information (for health insurance or leave purposes) and Drug test results (if applicable)
• Employee Relations:  Employee surveys and feedback, Disciplinary records and Exit interviews
• Compliance and Legal:  Social media monitoring (if company policy allows)
• Miscellaneous Data Collection:  Biometric and Facial recognition data (e.g., fingerprints for time clocks)

5.    The purpose of our use of your personal information

Language Empire needs to process personal information to enter into an employment contract with you and to meet our obligations under your employment contract, for example, processing payroll, managing benefits and tracking work hours.
In addition, we are required to process data to ensure that we are complying with our legal obligations, for example, we are required to check an employee’s entitlement to work in the UK and collect your tax information.  For certain positions, it is necessary to carry out criminal records checks to ensure that individuals are permitted to undertake a particular role.
In other cases, we have a legitimate interest in processing personal data before, during and after the end of the employment relationship for example performance evaluations, tracking professional development, internal planning and forecasting.
We will only use your medical information or emergency contact personal details in your vital interest to respond to emergencies at work.

6.    How We Use Sensitive Personal Information

Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (for example, concerning employees with disabilities and for health and safety purposes).
Language Empire uses other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or philosophical belief, this is done for the purposes of meaningful equal opportunities monitoring or reporting.]
[Data used by the Company for these purposes is anonymised or is collected with the express consent of employees, which can be withdrawn at any time. Employees are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.]

7.    Criminal Record Declarations and Background Checks

Depending on your role, you may be required to complete a Criminal Record Declaration. This aligns with our commitment to maintaining the highest standards of security and integrity across our operations.  The specific requirements are based on UK local laws and regulations.  We ensure that all our practices comply with local employment laws and data protection regulations in each jurisdiction where we operate.

8.    Automated Decision-Making

Our employment decisions are not based solely on automated decision-making.

9.    Change of Purpose

Language Empire will only use your personal information for the purpose for which it was collected unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use your personal information for an unrelated purpose, we will advise you of this and explain the legal basis which allows us to do so.
You should be aware that we may process your personal information without your knowledge or consent where this is required or permitted by law.

10.  Sharing your personal information

Your information will be shared internally, including with members of the HR (including payroll), Customer Service, Bookings, Translations, Recruitment, and Linguist Relations teams
The Company shares your data with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.  Third-party service providers carry out the following services: the accountant, external HR advisor, and HMRC. The Company may also share your data with other third parties, for example, in the context of a sale of some or all of its business. In those circumstances, the data will be subject to confidentiality arrangements.
Your data may be transferred to countries outside the UK to facilitate administrative purposes. Data is transferred outside the UK based on standard contractual clauses approved by the UK Information Commissioner’s Office. If you require further information, it is available upon request from the Data Protection Officer.

11. Transfers of your personal information overseas

There may be occasions when we transfer your data outside the UK, for example, if we communicate with you using a service provider that operates outside the UK, or if we seek a reference from a person outside the UK. Such transfers will only take place if one of the following applies:

• the country receiving the data is considered by the UK to provide an adequate level of data protection;
• the organisation receiving the data is covered by an arrangement recognised by the UK as providing an adequate standard of data protection;
• the transfer is governed by approved contractual clauses;
• the transfer has your consent;
• the transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract;
• the transfer is necessary for the performance of a contract with another person, which is in your interests;
• the transfer is necessary in order to protect your vital interests or of those of other persons, where you or other persons are incapable of giving consent;
• the transfer is necessary for the exercise of legal claims; or
• the transfer is necessary for important reasons of public interest.

12.  Ways we protect your personal information

Language Empire prioritizes the security and protection of personal information.  We have implemented internal policies and controls to prevent the loss, accidental destruction, misuse, or unauthorised disclosure of personal information.  Access is restricted to trained employees who require this information to perform their duties effectively.
When we engage third parties to process personal data on its behalf, they do so based on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data. 

13.  How long we keep your personal information

Language Empire will only hold your personal data for as long as is necessary to fulfil the purposes we collected it for, including any legal, accounting or reporting requirements. In general, the periods for which your data is held after the end of employment are

• General Employment Records: Retained for the duration of employment plus an additional 6 years after termination.
• Payroll Records: Retained for at least 6 years after the tax year.
• Health Records: Retained for the duration of employment plus 3 years, especially if they relate to disability or other long-term health issues.
• Pension Records: Pension-related information should be retained for at least 6 years after the end of the employee’s service.
• Performance Reviews and Disciplinary Records: Usually kept for a minimum of 6 years after the employee leaves the organization.

14.  If You fail to Provide Personal Information

If you do not prove certain information when requested, Language Empire may not be able to perform the contract we have entered into with you, such as paying you or providing a benefit.  You may also have to provide us with data to exercise statutory rights, for example concerning statutory leave entitlements.

15.  Your Rights

You have the following rights concerning your personal information:

• Right to Access: You have the right to request access to your personal information.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete data.
• Right to Erasure: You may ask us to delete your personal information, subject to certain conditions.
• Right to Restrict Processing: You can request that we limit the processing of your data.
• Right to Data Portability: You can request a copy of your personal information in a structured, commonly used, and machine-readable format.
• Right to Object: You can object to the processing of your personal information based on legitimate interests or for marketing purposes.

To exercise any of these rights, please contact us using the details provided below.

16.  Right to complain

If you are unhappy with the processing of your personal information, you should contact the Data Protection Officer in the first instance. You also have the right to complain to the supervisory authority if you consider that your data protection rights have been breached. The supervisory authority is the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, https://ico.org.uk/
Further details about your rights and the complaints process can be found on the Information Commissioner’s website.

17.  Keeping your personal data up-to-date

The data we hold about you must be accurate and current. Please keep us informed of any changes that may be necessary during your working relationship with us.

18.  Changes to This Privacy Notice

We may update this privacy notice from time to time. Any changes will be posted on our website, and where appropriate, notified to you by email.

19.  Contact the Data Protection Officer

If you’d like to put any of your rights into effect or make a complaint, please contact the Data Protection Officer. We’ll respond within one calendar month of receiving your request. Please email gdpr@empire-groupuk.com .

Director
Fasil Zaman
10/10/2024