Employee Privacy Policy

For the purpose of UK and Jersey data protection laws, the joint controllers are:

• Agria Pet Insurance Limited who is a limited company registered in England with the company registration number 04258783 and registered address 1st Floor, The Blue Leanie, Walton Street, Aylesbury, HP21 7QW.
• Agria Försäkring who is the insurance underwriter and based in the same location as Agria Pet Insurance Limited, is the UK establishment of Forsakringsaktiebolaget Agria (Publ) with the company number FC031808 and is a limited liability company incorporated in Sweden.

We process your personal data in line with the UK General Data Protection Regulation (UK GDPR), The Data Protection Act 2018 and any other relevant data protection legislation.

Personal data, or personal information, means any information about an individual from which
that person can be identified.

We will collect, store, and use the following categories of personal information about you:

• Personal contact details (including name, title, email address, postal address, and telephone numbers).
• Date of birth.
• Gender.
• Marital status and dependants.
• Employment information (including national insurance number, start date, leaving date and your reason for leaving, job titles, salary, bank details, annual leave taken, pensions and benefits information, location of employment or workplace, education and qualification records, records relating to your working hours, work history, training
  records, performance information, records of any formal processes (e.g. disciplinary and grievance)), documentation relating to any sickness absence including occupational health and GP reports (where applicable).
• Recruitment information (including copies of right to work documentation, references, your CV, job application, interview notes, pre-employment check records, identification documentation provided to us by you).
• Usernames or passwords for any online accounts you have set up with us.
• Bank details, payroll records and tax status information.
• Next of kin and emergency contact information.
• Copy of driving license (if necessary).
• Your nominated family members driving license details (if necessary).
• Details recorded in telephone calls that are monitored.
• Information about your use of our information and communications systems, CCTV footage and swipe card records which are controlled by the building management company.
• Photographs

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

• Information about your race or ethnicity, religious beliefs, sexual orientation, political opinions and/or trade union representative (where you have offered this information to us).
• Details about your health, including any medical condition, disabilities, or special requirements you may have recorded with us.
• Medical information relevant to any occupational health assessments, or reports completed by medical experts, completed in relation to your employment with us.
• Sickness and absence information (including in relation to time on statutory parental leave).
• Information about criminal convictions and offences (including driving convictions, civil proceedings, regulatory investigations) in relation to your employment or the controlled function (Appointed Representatives) you perform.

We collect personal information about you through the application and recruitment process, either directly from job applicants 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. When applying to undertake a Senior Management, Certification or Controlled Function (Appointed Representative), we will collect your personal information via the Financial Contact Authority (FCA) application form and onboarding process. We collect basic personal identifiers via the Approved Person for those undertaking insurance distribution activities on behalf of an Appointed Representative.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances: 

(a) Where we need to perform the contract, we have entered with you.

(b) Where we need to comply with a legal obligation.

(c) Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

(a) Where we need to protect your interests (or someone else's interests).

(b) Where it is needed in the public interest.

We need all the categories of personal information in the list above, primarily to allow us to perform our contract with you [*] and to enable us to comply with legal obligations [**]. In some cases, we may use your personal information to pursue legitimate interests [***], provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information, as well as providing a description of which categories of data are involved. Where a legitimate interest is involved, we state what the legitimate interest is.

• Making a decision about your recruitment or appointment using Recruitment
• information (e.g. references, your CV, job application, interview notes). [*], [***]
• Applying to the Financial Conduct Authority for a Senior Management, Certification or
• Controlled Function (Appointed Representative). [*], [***]
• To administer training and competency requirements in line with the Appointed
• Representative Regime. [*], [***]
• Determining the terms on which you work for us. [*], [***]
• Checking you are legally entitled to work in the UK. [*], [***]
• Paying you and, if you are an employee or deemed employee for tax purposes,
• deducting tax, National Insurance contributions (NICs) and any other financial
• arrangements including student loan deductions. [*], [***]
• Provide employee benefits to you via approved third party suppliers. [*]
• Enrolling you in a pension arrangement in accordance with our statutory automatic
• enrolment duties. [*]
• Administering the contract we have entered with you. [*], [***]
• Business management and planning, including accounting and auditing. [*], [***]
• Conducting performance reviews, managing performance, and determining
• performance requirements. [*], [***]
• Making decisions about salary reviews and compensation. [*], [***]
• Assessing qualifications for a particular job or task, including decisions about
• promotions. [*], [***]
• Gathering evidence for possible grievance or disciplinary hearings. [*], [***]
• Making decisions about your continued employment or engagement. [*], [***]
• Making arrangements for the termination of our working relationship. [*], [***]
• Education, training, and development requirements. [*], [***]
• Dealing with legal disputes involving you, or other employees, workers, and
• contractors, including accidents at work. [*], [***]
• Ascertaining your fitness to work including managing sickness absence. [*], [***]
• Complying with health and safety obligations, including our own internal health and
• safety policy. [*], [***]
• To prevent fraud. [*], [***]
• To monitor your use of our information and communication systems to ensure compliance with our IT policies. [*], [***]
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution. [***]
• Equal opportunities monitoring. [**]
• To report mental health emergencies to the appropriate emergency services or health professionals in a reasonable and proportionate way. [**]

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information for the purposes for which we collected it, 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 notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Situations in which we will use your sensitive personal information

In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so or where we believe that you are at risk of causing serious harm to yourself, or others, because of your mental health (mental health emergency). The situations in which we will process your particularly sensitive personal information are listed below.

• We will use information about your physical or mental health, to:
• ensure your health and safety in the workplace;
• report your condition to appropriate emergency services or health professionals in the event of a mental health emergency;
• assess your fitness to work;
• provide appropriate workplace adjustments;
• monitor and manage sickness absence; and
• administer benefits including statutory maternity pay, statutory sick pay and pensions.

If we reasonably believe that you or another person are at risk of harm and the processing is necessary to protect you or them from physical, mental, or emotional harm or to protect physical, mental, or emotional well-being.

We will use information about your race, nationality, or ethnic origin, religious, philosophical, or moral beliefs, or your sexual orientation to ensure meaningful equal opportunity monitoring and reporting.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences in the following ways:

• Applying to the Financial Conduct Authority for a Senior Management, Certification or Controlled Function (Appointed Representative).
• Making a decision about your recruitment or appointment.
• Monitoring your ongoing fitness and propriety in relation to the contract you are party to with us.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

We do not need your consent where the purpose of the processing is to protect you or another person from harm or to protect your well-being and if we reasonably believe that you need care and support, are at risk of harm and are unable to protect yourself.

We will not contact you for marketing purposes.

We do not use your personal data for any automated decision making or profiling.

We may share your data outside the UK; however, we do not transfer any data outside of the European Economic Area (EEA). Any personal data shared outside of the UK is done so in line
with the relevant data protection laws.

• Our professional advisors (including solicitors, bankers, auditors, pension administration, benefits provision, and insurers) and quality assurance assessors for the purpose of taking advice or if we are under a duty to comply with a legal obligation.
• Our landlord, property management company, and building security providers for the purposes of health, safety, and security.
• Selected suppliers for the purpose of paying expenses.
• Selected suppliers for the purpose of delivery, collection, use and tracking of company vehicles.
• Selected suppliers to undertake due diligence, pre-employment checks and ongoing oversight for the purpose of making informed decisions about your proposed or existing employment and to comply with a legal obligation.
• Selected third parties including independent HR consultancies & advice services, medical experts, occupational health service providers, and independent training providers including training software providers for the purpose of managing the employee lifecycle to the extent that it is necessary for our legitimate business interests.
• Selected third parties including software providers that provide software and services relating to the management of payroll, absence, contractual and non-contractual employee benefits for the purpose of managing the employee lifecycle to the extent that it is necessary for our legitimate business interests.
• Selected suppliers for the purpose of supplying, delivery, and collection of IT hardware equipment.
• We may also disclose or share your personal information with third parties to comply with a legal obligation, or to enforce or apply any contract between you and us, or to protect the rights, property, or safety of Agria, our employees, or others.
• Relevant emergency services or health professionals in the event of a mental health emergency.
• Selected suppliers for the purpose of sending gifts and rewards.

All individuals have rights under data protection legislation, which are listed below. Agria have measures and processes in place to deal with any requests made when exercising these rights.

Right to be informed

You have the right to be informed about the collection and use of your personal data. This information must be concise, transparent, intelligible, easily accessible, and it must be in clear and plain language. We provide this to you in the form of this privacy policy.

Right of access

You can request all personal data that we hold on you. You have the right to contact us to request this using one of the contact methods stated below. We will review this and provide you with the information we have at the earliest opportunity, however, if the request is complex, we will contact you within 30 days to explain this and we may charge a fee for this if the request is excessive and/or manifestly unfounded. This right is also known as a ‘subject access request’.

Right to rectification

You have the right to rectification if your personal data is inaccurate or incomplete. We strive to ensure that we have the most accurate and up to date data, however, please advise us as soon as possible, if any of the information we hold on you is inaccurate, and we will rectify it.

Right to erasure

You can request that your personal data is removed or deleted where there is no legal basis or compelling reason for this data to be processed any longer. This right is more commonly known as the ‘right to be forgotten’.

Right to restrict processing

You have the right to request that the processing of your data is restricted in circumstances such as when you contest the accuracy of the data or when the processing is unlawful.

Right to data portability

Data portability allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability.

Right to object

You have the right to object to the processing of your personal data if you do not wish for it to be used for direct marketing purposes, and we must act on this. You can also object to any use of information where we have given ‘legitimate interest’ as our reason for using it. You must provide us with the reason for the objection and how it affects you as an individual.

Right not to be subject to a decision based solely on automated processing

You have the right to ask for human intervention where a decision has solely been or is due to be made by automated means.

Where you have provided consent for us to process the data that we hold on you, you have the right to withdraw your consent that you provided to us at any time. If you have provided us with your explicit consent to process your data, you can withdraw this at any time.

You have the right to lodge a complaint about the processing of your personal data with a Supervisory Authority. The relevant Supervisory Authority is The Information Commissioners Office (ICO), please visit their website which advises you of the best method to contact them, www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

We will keep your personal data and telephone conversations for a period of 7 years after your employment or contract has ceased or the end of any ongoing employment or payment
disputes, whichever is the latter. We are required to retain your data for this period of time by law and to defend potential legal claims. For all personal data that we retain, 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, and the
applicable legal requirements.

We have a Data Protection Manager who has a high-level responsibility for monitoring compliance with all relevant data protection regulations and is the lead contact for liaison with The Information Commissioners Office (ICO). To exercise any of your rights mentioned above or with any specific queries on the personal data we hold on you, please contact us by post or
email using the details below:

The Data Protection Manager
Agria Pet Insurance Limited
1st Floor
The Blue Leanie
Walton Street
Aylesbury
Bucks
HP21 7QW
Email: dataprotection@agriapet.co.uk