Host Staffing Ltd ("Host Staffing", "the Company", "we", "us") is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you before, during and after your working relationship with us, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Who we are

Host Staffing Ltd is the "data controller" of the personal information described in this notice. This means we are responsible for deciding how we hold and use personal information about you. Our details are:

  • Registered company name: Host Staffing Ltd
  • Company number: 10120220
  • Registered address: 86-94 High Street, TW3 1NH, London.
  • Data protection contact: gdpr@host-staffing.co.uk

We are not required to appoint a statutory Data Protection Officer. Our data protection contact above is responsible for overseeing questions about this notice and how we handle your personal information.

Who this notice applies to

This notice applies to applicants and candidates registering with us, and to current and former employees, workers and contractors. It does not form part of any contract of employment or other contract to provide services. We may update this notice at any time, and we will tell you when we make substantial changes.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

The kind of information we hold about you

Depending on your relationship with us, we may hold:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
  • Date of birth.
  • Gender.
  • Marital status and dependants.
  • Next of kin and emergency contact information.
  • National Insurance number.
  • Bank account details, payroll records and tax status information.
  • Pay, annual leave, pension and benefits information.
  • Start date.
  • Location of assignment or workplace.
  • Copy of driving licence.
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
  • Engagement records (including job titles, work history, working hours, shift and timesheet records, training records and professional memberships).
  • Pay history.
  • Performance information, including ratings, notes and feedback recorded in connection with your shifts.
  • Disciplinary and grievance information.
  • CCTV footage (where applicable) and other information obtained through electronic means such as swipecard or clock-in records.
  • Information about your use of our information and communications systems, including our staff portal.
  • Photographs.

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

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Trade union membership.
  • Information about your health, including any medical condition, health and sickness records.
  • Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about applicants, employees, workers and contractors through the application and registration process, either directly from you 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 (where applicable) or other background check agencies.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us, including from the client venues at which you work.

Situations in which we will use your personal information

We need all the categories of information listed 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 of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

  • Making a decision about your recruitment, registration or appointment.
  • Determining the terms on which you work for us.
  • Checking you are legally entitled to work in the UK.
  • Offering you shifts and assignments, and managing bookings, rotas and timesheets.
  • Paying you and, where applicable, deducting tax and National Insurance contributions.
  • Providing company benefits (where applicable).
  • Liaising with your pension provider.
  • Administering the contract we have entered into with you.
  • Providing our clients with the information they need to receive our services, including confirming who is attending an assignment.
  • Business management and planning, including accounting and auditing.
  • Conducting performance reviews, managing performance and determining performance requirements.
  • Making decisions about pay 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.
  • Managing sickness absence.
  • Complying with health and safety obligations.
  • 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.
  • To conduct data analytics studies to review and better understand worker retention and attrition rates.
  • Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

Our lawful bases for processing

We rely on the following lawful bases under Article 6 of the UK GDPR:

  • Performance of a contract with you, or to take steps at your request before entering into a contract — for example registering you, offering you shifts, and paying you.
  • Compliance with a legal obligation — for example right to work checks, tax and National Insurance, working time records, and health and safety obligations.
  • Our legitimate interests, or those of a third party — for example running our business efficiently, preventing fraud, securing our systems, managing performance and quality of service to our clients, and keeping records to defend legal claims. Where we rely on legitimate interests, we have considered whether your interests and rights override ours.
  • Protecting someone's vital interests — in rare cases, such as a medical emergency at work.
  • Your consent — used only in limited circumstances, which we will make clear at the time. Where we rely on consent, you can withdraw it at any time.

We do not rely on consent as the lawful basis for the routine processing described in this notice.

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 into with you (such as paying you or offering you shifts), 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.

How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

  1. Where we need to carry out our legal obligations or exercise rights in connection with employment, social security or social protection law (Article 9(2)(b) UK GDPR, together with Schedule 1, Part 1 of the Data Protection Act 2018).
  2. Where it is needed in the substantial public interest, such as for equal opportunities monitoring (Article 9(2)(g), together with Schedule 1, Part 2 of the Data Protection Act 2018).
  3. Where it is necessary for the establishment, exercise or defence of legal claims (Article 9(2)(f)).
  4. Where it is needed to protect your interests or someone else's interests and you are not capable of giving your consent (Article 9(2)(c)).
  5. Where you have already made the information public (Article 9(2)(e)).

Where we process special category or criminal offence data under Schedule 1 of the Data Protection Act 2018, we maintain an Appropriate Policy Document as required by Part 4 of that Schedule. A copy is available on request from gdpr@host-staffing.co.uk.

Our obligations as an employer

We will use your particularly sensitive personal information in the following ways:

  • We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
  • We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations (where applicable).

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our Appropriate Policy Document 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.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations, and is authorised by Schedule 1 of the Data Protection Act 2018.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

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.

Automated decision-making

We do not make decisions about you based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. Our platform may sort, filter or prioritise shift offers and worker lists automatically to help our staff work efficiently, but decisions about whether you are engaged, booked for a shift, or how you are paid always involve a member of our team.

If this changes, we will tell you and explain your rights, including the right to obtain human intervention, to express your point of view and to contest the decision.

Data sharing

We may have to share your data with third parties, including our clients and third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. In some cases, this involves transferring your personal information outside the UK.

Why might you share my personal information with third parties?

We will share your personal information 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.

Sharing with our clients

Where we place you on an assignment, we share the information the client needs in order to receive our services — for example your name, the shifts you are booked for, relevant qualifications or training, and any information they require to meet their own health and safety or licensing obligations. Our clients are separate data controllers in respect of the information we share with them and are responsible for how they use it. Where the client operates its own systems, such as CCTV or clock-in terminals at the venue, that processing is carried out under the client's own privacy notice.

Which third-party service providers process my personal information?

We use trusted third-party service providers who process your personal information on our behalf, under contract and only on our instructions. These currently include:

  • Microsoft Azure - secure hosting and storage of our platform and its data.
  • Microsoft - email and office services (for example, correspondence sent via Outlook).
  • SendGrid (Twilio) - sending automated emails such as notifications and account messages.
  • Reach Interactive - sending SMS text messages (for example, shift and booking notifications).
  • Flow Payroll - payroll processing and related payments.
  • Mapal OS - online training and onboarding modules we invite you to complete.
  • Anthropic - provides the AI assistant within our platform.

Some of these providers, or their infrastructure, are located outside the UK. Where your personal information is transferred outside the UK, we ensure a similar degree of protection by relying on appropriate safeguards, such as the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, or transfers to countries covered by UK adequacy regulations.

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator, with HMRC, or to otherwise comply with the law.

Data security

We have put in place measures to protect the security of your information. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In order 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, and the applicable legal requirements.

By way of example, we usually retain:

  • Payroll and tax records for [6] years after the end of the tax year to which they relate.
  • Right to work check documents for [2] years after the end of your engagement.
  • Working time and shift records for [3] years.
  • Unsuccessful applicant records for [12] months from the date of application.
  • Accident and injury records for [3] years from the date of the incident (longer where the incident involves a person under 18 or a potential long-tail claim).

Our full retention schedule is available on request from gdpr@host-staffing.co.uk.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. You can update most of your details directly in the staff portal.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to exercise any of these rights, please email gdpr@host-staffing.co.uk. We will respond within one month, although we may extend this by up to two further months for complex requests, in which case we will let you know.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email gdpr@host-staffing.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another lawful basis for doing so.

Your right to complain

We would prefer you to raise any concerns with us first, so we have the chance to put things right. Please contact gdpr@host-staffing.co.uk.

You also have the right to complain at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues:

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact gdpr@host-staffing.co.uk.