Data Privacy Notice
AETN UK
Data Privacy Notice for Staff and Job Applicants
Issued: 29 May 2018
1. Introduction
AETN UK ("A+E Networks", "we" or "us") has issued this Data Privacy Notice (“Notice”) to describe how we handle personal information that we hold about our staff and job applicants (collectively referred to as "you"). The term "staff member" includes those who work on a non-permanent basis, including contingent workers, temporary and contract workers, independent contractors, consultants, professional advisors, secondees and interns.
We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. This Notice sets out the personal information that we collect and process about you, the purposes of the processing and the rights that you have in connection with it.
If you are in any doubt regarding the applicable standards, or have any comments or questions about this Notice, please contact HR.
2. Types of personal information we collect
In the course of your employment at A+E Networks, or when making an application for employment, we may process personal information about you and your dependents, beneficiaries and other individuals whose personal information has been provided to us.
The types of personal information we may process include, but are not limited to:
Identification data – such as your name, gender, photograph, date of birth, staff member IDs.
Contact details – such as home and business address, telephone/email addresses, emergency contact details.
Employment details – such as job title/position, office location, employment contract, performance and disciplinary records, grievance procedures, sickness/holiday records.
Background information – such as academic/professional qualifications, education, CV/résumé, criminal records data (for vetting purposes, where permissible and in accordance with applicable law).
National identifiers – such as national ID/passport, national registration number, immigration/visa status.
Spouse, dependents and marital status information for such purposes of signing you and your spouse and dependents up to the Life Assurance, Private Medical Insurance or Virtual GP benefits.
Financial information – such as banking details, tax information, withholdings, salary, benefits, expenses, and company allowances.
IT information – information required to provide access to company IT systems and networks such as IP addresses, log files and login information. For further information on how IT information is processed, please speak to IT.
If you are a contingent worker, the type of personal information we process is limited to that needed to manage your particular work assignment with A+E Networks.
Sensitive personal information includes any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, genetic data, biometric data for the purposes of unique identification, trade union membership, or information about your health/sex life ("Sensitive Personal Information"). As a general rule, we try not to collect or process any Sensitive Personal Information about you, unless authorised by law or where necessary to comply with applicable laws.
However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Sensitive Personal Information for legitimate employment-related purposes: for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations; or information about your physical or mental condition to provide work-related accommodations, health and insurance benefits to you and your dependents, or to manage absences from work.
3. Purposes for processing personal information
(i) Recruitment purposes
If you are applying for a role at A+E Networks, then we collect and use this personal information primarily for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying our reference checks or background checks (where applicable and where permitted by law) and to generally manage the hiring process and communicate with you about it.
If you are accepted for a role at A+E Networks, the information collected during the recruitment process will form part of your ongoing staff member record.
If you are not successful, we may still keep your application to allow us to consider you for other suitable openings within A+E Networks in the future.
(ii) Employment or work related purposes
Once you become a staff member at A+E Networks, we collect and use this personal information for the purpose of managing our employment or working relationship with you – for example, your employment records and contract information (so we can manage our employment relationship with you), your bank account and salary details (so we can pay you), details of your spouse and dependents (for emergency contact and benefits purposes) and your contact and identification information (for travel purposes).
We process our staff members' personal information through a global human resources system ("HR System"), which is a tool that helps us to administer HR and staff member compensation and benefits at an international level and which allows staff members to manage their own personal information in some cases. Your personal information is held in UK data centres but we may share your personal information with our parent company in the US, A&E Television Networks, LLC, and our office in South Africa, but in either case will be responsible for the security access of personal information on the HR System.
(iii) The A+E Networks global directory
We maintain a directory of staff members which contain your professional contact details (such as your name, location, photo, job title and contact details). This information is made available to everyone who work across offices based in the following territories: England, Denmark, the Netherlands, Poland and South Africa.
(iv) Other legitimate business purposes
We may also collect and use personal information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently – for example, for general HR resourcing, salary reviews, expense tracking and reimbursement, management reporting and analysis, training and development, IT support, compensation, employee career development, IT security/management, accounting purposes, or financial planning. We may also process your personal information to investigate violations of law or breaches of our own internal policies.
(v) Law-related purposes
We also may use your personal information where we consider it necessary for complying with laws and regulations, including collecting and disclosing staff member personal information as required by law (e.g. for tax, health and safety, anti-discrimination laws) or to exercise or defend the legal rights of the A+E Networks global group of companies.
4. Who we share your personal information with
We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of the information is maintained.
(i) Transfers to other group companies
As mentioned above, we will share your personal information with other members of the A+E Networks group around the world in order to administer human resources, staff member compensation and benefits at an international level on the HR System, as well as for other legitimate business purposes such as IT services/security, tax and accounting, and general business management.
(ii) Transfers to third party service providers
In addition, we make certain personal information available to third parties who provide services to us. We do so on a "need to know basis" and in accordance with applicable data privacy law.
For example, some personal information will be available to our benefit plan service providers and third party companies who provide us with payroll support services, recruitment services, learning and development services and salary benchmarking services.
(iii) Transfers to other third parties
We may also disclose personal information to third parties on other lawful grounds, including:
To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant
In response to lawful requests by public authorities (including for national security or law enforcement purposes)
As necessary to establish, exercise or defend against potential, threatened or actual litigation
Where necessary to protect the vital interests of another person
In connection with the sale, assignment or other transfer of all or part of our business
With your consent.
5. Legal basis for processing personal information (EEA staff only)
If you are a staff member in the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you (i.e. to administer an employment or work relationship with us), or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at Section 10 below.
6. Transfer of personal information abroad
As we operate at a global level, we may need to transfer personal information to countries other than the ones in which the information was originally collected, for example to our group companies and third party service providers who operate across the world. When we export your personal information to a different country, we will take steps to ensure that such data exports comply with applicable laws. For example, if we transfer personal information from the European Economic Area to a country outside it, such as the United States, we will implement an appropriate data export solution such as entering into EU standard contractual clauses with the data importer, or taking other measures to provide an adequate level of data protection under EU law.
We are implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law. Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and further details can be provided upon request.
7. Data retention periods
Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally this means your personal information will be retained until the end or your employment, employment application, or work relationship with us plus a reasonable period of time thereafter to respond to employment or work-related inquiries or to deal with any legal matters (e.g. judicial or disciplinary actions), document the proper termination of your employment or work relationship (e.g. to tax authorities), or to provide you with ongoing pensions or other benefits. If you have any questions on retention periods, please contact aetnhr@aetn.co.uk.
8. Your data privacy rights
You may exercise the rights available to you under applicable data protection laws as follows:
If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided at Section 10 below.
In addition, if you are a resident of the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided at Section 10 below.
If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries are available here.)
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
9. Updates to this Notice
This Notice may be updated periodically to reflect any necessary changes in our privacy practices. In such cases, we will inform you by email and indicate at the top of the Notice when it was most recently updated. We encourage you to check back at this website periodically in order to be aware of the most recent version of this Notice.
10. Contact details
Please address any questions or requests relating to this Notice to aetnhr@aetn.co.uk or alternatively, you can raise any concerns with your line manager or the legal team.