Privacy Policy

Like most businesses, we hold and process a wide range of information, some of which relates to individuals who work for us. This Workplace Privacy Notice explains the type of information we process, why we are processing it and how that processing may affect you.

The notice focuses on individuals who work for us, whether employed by us or not. It also covers information on former employees.

This Workplace Privacy Notice is set out in this document (the Core Notice) and Annex 1- Supplementary Information. We have also provided more specific information in Annex 2.

In the Supplementary Information, we explain what we mean by “personal data”, “processing”, “sensitive personal data” and other terms used in the notice.

In brief, this notice explains:

  • What personal data we hold and why we process it;
  • The legal grounds which allow us to process your personal data;
  • Where the data comes from, who gets to see it and how long we keep it;
  • How to access your personal data and other rights;
  • How to contact us

PERSONAL DATA - WHAT WE HOLD AND WHY WE PROCESS IT

We process data for the purposes of our business including management, administrative, employment and legal purposes. The Supplementary Information provides more specific information on these purposes, on the type of data that may be processed and on the grounds on which we process data. See legal grounds for processing personal data and further information on the data we process and our purposes.

WHERE THE DATA COMES FROM AND WHO GETS TO SEE IT

Some of the personal data that we process about you comes from you. For example, you tell us your contact and banking details.

Other personal data about you is generated in the course of your work, for example, from your Managers, colleagues and customers or others outside our organisation with whom you deal.Your personal data will be seen internally by Managers, HR and, in some circumstances, colleagues. We will where necessary and as set out in this privacy notice also pass your data outside the organisation, for example to people you are dealing with and payroll agencies.

Further information on this is provided in the Supplementary Information. See ‘Where the data comes from’ and ‘Who gets to see your data?’

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We do not keep your personal data for any specific period but will not keep it for longer than is necessary for our purposes. In general, we will keep your personal data for the duration of your employment and for a period afterwards. See ‘Retaining your Personal Data’ – more information can be found in the Supplementary Information.

YOUR DATA RIGHTS

You have a right to make a subject access request to receive information about the data that we process about you. Further information on this and on other rights is in the Supplementary Information under ‘Access to your personal data and other rights’. We also explain how to make a complaint about our processing of your data.

CONTACT DETAILS

In processing your personal data, we act as a data controller. Our contact details are set out in Annex 2.Please note that generally the data controller of your personal data will be your employing/engaging entity but also entities within the Hollywood Bowl Group with which we share data for business administration purposes.

STATUS OF THIS NOTICE

This notice does not form part of your contract of employment and does not create contractual rights or obligations. It may be amended by us at any time. Nothing in this notice is intended to create an employment relationship between us and any non-employee providing services to us.

ANNEX 1 - SUPPLEMENTARY INFORMATION

What do we mean by "personal data" and "processing"?

“Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you, but also intentions and opinions about you.

Data “processed automatically” includes information held on, or relating to use of, a computer, laptop, mobile phone or similar device. It covers data derived from equipment such as access passes within a building, data on use of vehicles and sound and image data such as CCTV or photographs.

"Processing" means doing anything with the data. For example, it includes collecting it, holding it, disclosing it and deleting it.

Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by EU privacy law to be “sensitive personal data”.

References in the Privacy Notice to employment, work (and similar expressions) include any arrangement we may have under which an individual provides us with work or services. By way of example, when we mention an “employment contract” that includes a contract under which you provide us with services; when we refer to ending your employment, that includes terminating a contract for services. We use the word “you” to refer to anyone within the scope of the notice.

LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

What are the grounds for processing?

Under data protection law, there are various grounds on which we can rely when processing your personal data. In some contexts more than one ground applies. We have summarised these grounds as Contract, Legal obligation, Legitimate Interests and Consent and outline what those terms mean in the following table.

Term

Ground for processing

Explanation
Contract Processing necessary for performance of a contract with you or to take steps at your request to enter a contract. This covers carrying out our contractual duties and exercising our contractual rights
Legal obligation Processing necessary to comply with our legal obligations. Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination.
Legitimate interests Processing necessary for our or a third party’s legitimate interests.

We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data.

Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.

Consent You have given specific consent to processing your data. In general processing of your data in connection with employment is not conditional on your consent. But there may be occasions where we do specific things such as getting a criminal record check for a role which is regulated and rely on your consent to our doing so.

PROCESSING SENSITIVE PERSONAL DATA

If we process sensitive personal data about you (for example (but without limitation), storing your health records to assist us in ensuring that we provide you with a healthy and safe work workplace or processing personal data relating to diversity monitoring), as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one or more of the grounds for processing sensitive personal data applies. In outline, these include:

  • Processing being necessary for the purposes of your or our obligations and rights in relation to employment in so far as it is authorised by law or collective agreement;
  • Processing relating to data about you that you have made public (e.g. if you tell colleagues that you are ill);
  • Processing being necessary for the purpose of establishing, making or defending legal claims;
  • Processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity;
  • Processing for equality and diversity purposes to the extent permitted by law

FURTHER INFORMATION ON THE DATA WE PROCESS AND OUR PURPOSES

The Core Notice outlines the purposes for which we process your personal data. More specific information on these, examples of the data and the grounds on which we process data are in the table below.

The examples in the table cannot, of course, be exhaustive. For example, although the table does not mention data relating to criminal offences, if we were to find out that someone working for us was suspected of committing a criminal offence, we will process that information if necessary for our purposes. If necessary we will also require criminal background checks for certain roles – for example those working in financial roles or working with minors.

Term

Ground for processing

Explanation

Recruitment

Standard data related to your identity (e.g. your name, address, email address, ID information and documents, telephone numbers, place of birth, nationality, contact details, professional experience and education (including university degrees, academic records, professional licenses, memberships and certifications, awards and achievements, and current and previous employment details), financial information (including current salary information) language skills, and any other personal data that you present us with as part of your application related to the fulfillment of the role.

Information concerning your application and our assessment of it, your references, any checks we may make to verify information provided or background checks and any information connected with your rights to work.

If necessary, we will also process information concerning your health, any disability and in connection with any adjustments to working arrangements.

Contract

Legal obligation

Legitimate interests

Your employment contract including entering it, performing it and changing it

Information on your terms of employment from time to time including your hours and working patterns and your pay and benefits such as your participation in pension arrangements, life and medical insurance; and any bonus or share schemes.

Contract

Legal obligation

Legitimate interests

Contacting you or others on your behalf Your address and phone number, emergency contact information and information on your next of kin.

Contract

Legal obligation

Legitimate interests

Payroll administration

Information on your bank account, pension contributions and on tax and national insurance.

Your national insurance number or other government issued identifier.

Information on attendance, holiday and other leave and sickness absence.

Contract

Legal obligation

Legitimate interests

Financial planning and budgeting Information such as your salary and (if applicable) bonus levels. Legitimate interests
Supporting and managing your work and performance and any health concerns

Information connected with your work, anything you do at work and your performance including records of documents and emails created by or relating to you and information on your use of our systems including computers, laptops or other device.

Management information regarding you including notes of meetings and appraisal records, including information you or our managers enter onto our training or appraisal platforms.

Information relating to your compliance with our policies.

Information concerning disciplinary allegations, investigations and processes and relating to grievances or complaints in which you are or may be directly or indirectly involved.

Information concerning your health, including medical or doctors’ notes, return to work plans, and medical and occupational health reports.

Contract

Legal obligation

Legitimate interests

Changing or ending your working arrangements

Information connected with anything that may affect your continuing employment or the terms on which you work including any proposal to promote you, to change your pay or benefits, to change your working arrangements or to end your employment.

Contract

Legitimate interests

Physical and system security

CCTV images.

Your IT account and directory information.

Records of use of swipe and similar entry cards.

Records of your use of our systems including computers, phones and other devices and passwords.

Legal obligation

Legitimate interests

Improving efficiency of IT and business systems and device use

Records of your use of IT and business systems and Hollywood Bowl Group devices.

For example, we may collect information on the number of minutes and amount of data used on company mobile phones to ensure employees are on the most cost-effective tariff for their usage.

We will where necessary and as set out in this privacy notice also contract with third parties so you can use third party applications on your company devices which may assist with your work (for example an application allowing ‘one-click’ dial in to conference calls). Such applications will process your personal data. Their own privacy notices will make clear precisely what information will be collected. We may be provided with information on the usage of such applications, for example for the purpose of troubleshooting or assessing overall usage and whether to continue to provide them.

Legitimate interest
Providing references in connection with your finding new employment Information on your working for us and on your performance.

Consent

Legitimate interests

Providing information to third parties in connection with transactions that we contemplate or carry out Information on your contract and other employment data that may be required by a party to a transaction such as a prospective purchaser, seller or outsourcer. Legitimate interests
Monitoring of diversity and equal opportunities Information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age as part of diversity monitoring initiatives. Such data will aggregated and used for equality of opportunity monitoring purposes. Please note we may share aggregated and anonymous diversity statistics with regulators if formally required/requested. Legitimate interests
Monitoring and investigating suspicions of misconduct, compliance with policies and rules – both generally and specifically We expect our employees and workers to comply with our policies and rules and may monitor our systems to check compliance (e.g. rules on accessing pornography at work). We will where necessary and as set out in this privacy notice check system and other data to look into those concerns (e.g. log in records, records of usage and emails and documents, CCTV images). We do not give employees or workers the permission to record any meetings on any devices. In appropriate cases if we have suspicions of serious wrong-doing, we may make targeted records (e.g. video or sound) in connection with an investigation.

Legitimate interests

Disputes and legal proceedings Any information relevant or potentially relevant to a dispute or legal proceeding affecting us.

Legitimate interests

Legal obligation

Trade union check off arrangements and Works Council administration

Details of trade union membership and deductions of contributions made at source.

Information relating to Works Council participation, including any communication you send to us if acting for the Works Council (if applicable).

Contract

Legal Obligation

Day to day business operations including marketing and customer/client relations and travel on our behalf.

Information relating to the work you do for us, your role and contact details including relations with current or potential customers or clients. This may include a picture of you for internal or external use.

Information regarding your travel arrangements and location.

Legitimate interests
Maintaining appropriate business records during and after your employment Information relating to your work, anything you do at work and your performance relevant to such records.

Contract

Legal obligation

Legitimate interests

Communication and Recognition

Photographs and images may be used of you taken with your knowledge in the workplace.

Photographs and images may be used of you if you have provided them.

They may be used on our internal newsletter or intranet.

Legitimate interests

WHERE THE DATA COMES FROM

When you start employment with us, the initial data about you that we process is likely to come from you: for example, contact details, bank details and information on your immigration status and whether you can lawfully work. We will where necessary and as set out in this privacy notice also require references and information to carry out background checks. In the course of employment, you may be required to provide us with information for other purposes such as sick pay (and SSP) and family rights (e.g. maternity and paternity leave and pay). If you do not provide information that you are required by statute or contract to give us, you may lose benefits or we may decide not to employ you or to end your contract. If you have concerns about this in a particular context, you should speak to HR.

In the course of your work, we may receive personal data relating to you from others. Internally, personal data may be derived from your Managers and other colleagues or our IT systems; externally, it may be derived from our Customers or those with whom you communicate by email or other systems.

WHO GETS TO SEE YOUR DATA?

INTERNAL USE

Where necessary and as set out in this privacy notice, your personal data will be disclosed to your Managers, HR and administrators for employment, administrative and management purposes as mentioned in this document. We will where necessary and as set out in this privacy notice also disclose this to other members of our group.

EXTERNAL USE

We will only disclose your personal data outside the group if disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you.

We will disclose your data if it is necessary for our legitimate interests as an organisation or the interests of a third party (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy). Where necessary, we will also disclose your personal data if you consent, where we are required to do so by law or in connection with criminal or regulatory investigations.

Specific circumstances in which your personal data may be disclosed include:

  • Disclosure to organisations that process data on our behalf such as our payroll service, insurers and other benefit providers, our bank and organisations that host our IT systems and data;
  • Disclosure to external recipients of electronic communications (such as emails) which contain your personal data;
  • Disclosure on a confidential basis to a potential buyer of our business or company for the purposes of evaluation – but only if we were to contemplate selling;
  • Disclosure and transfer disclosed to respond to law enforcement agency requests or where required by applicable laws, pursuant to court orders, or arbitral or tribunal orders or rules of procedure, or to government regulations departments or agencies or regulatory bodies (including disclosures to tax and employment authorities),employment and any other regulatory bodies);
  • Disclosure on a confidential basis to our advisers for example to our lawyers for the purposes of seeking legal advice or to further Hollywood Bowl Group’s interests in legal proceedings and to our accountants for auditing purposes;
  • Disclosure to our insurers;
  • Disclosure of aggregated and anonymised diversity data to relevant regulators as part of a formal request;
  • To third parties for the purpose of assessing efficiency of IT or business system device usage. In such cases the data sent to the third party will be anonymised where possible

RETAINING YOUR PERSONAL DATA – MORE INFORMATION

Although there is no specific period for which we will keep your personal data, we will not keep it for longer than is necessary for our purposes. In general, we will keep your personal data for the duration of your employment and for a period afterwards. In considering how long to keep it, we will take into account its relevance to our business and your employment either as a record or in the event of a legal claim.

If your data is only useful for a short period (for example, CCTV or a record of a holiday request), we will delete it in accordance with our Retention Policy.

Personal data relating to job applicants (other than the person who is successful) will normally be deleted after six months.

For more information please see our Retention Policy which can be found on STRIKES.

ACCESS TO YOUR PERSONAL DATA AND OTHER RIGHTS

We try to be as open as we reasonably can about personal data that we process. If you would like specific information, just ask us.

You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including:

  • Giving you a description and copy of the personal data
  • Telling you why we are processing it

If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.

As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted. If you have provided us with data about yourself (for example your address or bank details), you have the right to be given the data in machine readable format for transmitting to another data controller. This only applies if the ground for processing is Consent or Contract.

If we have relied on consent as a ground for processing, you may withdraw consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.

COMPLAINTS

If you have complaints relating to our processing of your personal data, you should raise these with HR in the first instance or with the Data Protection Officer. You may also raise complaints with your statutory regulator. For contact and other details ask HR.

STATUS OF THIS NOTICE

This notice does not form part of your contract of employment and does not create contractual rights or obligations. It may be amended by us at any time. Nothing in this notice is intended to create an employment relationship between us and any non-employee providing services to us.

Annex 2 – Information about Data Controllers

United Kingdom

If you are employed, engaged or otherwise in the UK the following additional information applies.

The statutory regulator is the ICO.

Data Protection Officer

Company

Email Address
Kate Wilson Hollywood Bowl Group gdprinfo@hollywoodbowl.co.uk

Please note that this Privacy Notice, along with other related Hollywood Bowl Group policies and/or protocols, shall form Hollywood Bowl Group’s policy for procuring special data as required by the UK Data Protection Bill 2018 (Schedule 1 Part IV).