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How we process employee data


Thames Reach collects, stores and uses employee data to manage the employment relationship. We are committed to protecting employee rights and freedoms and fully complying with the principles of data protection detailed in the EU General Data Protection Regulations, 2018.

This information should be read alongside the Thames Reach Privacy policy.

What information do we collect?

Thames Reach collects and processes a range of information about it employees, including:

– name, address and contact details (including emergency contacts)
– date of birth
– gender
– National Insurance number
– nationality and entitlement to work in the UK
– criminal convictions
– details of leave taken by you, including holiday, sickness absence, family and other leave
– details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you
– assessments of your performance, including appraisals and performance improvement plans

Data is collected in a variety of ways, for example, application forms that you fill in, CVs, identity documents that you provide us, forms completed by you at the start of your employment, health declarations, recruitment interviews, supervision sessions and appraisals or general correspondence with you.

How we use your data

Thames Reach processes your data in our legitimate capacity as your employer but we will only use your personal data as the law allows us to.

The lawful bases we use to process data are:

Our Contractual obligations as your employer, for example, to pay you or administer your pension entitlements.

Complying with a Legal obligation, i.e. checking an employee’s entitlement to work, calculating tax deductions, complying with court orders etc or if we need to share your data with a commissioner under TUPE law.

Our Legitimate interest in keeping accurate employment records, for example, performance assessments, supervision notes, and responding to and defending against legal claims.

It is also in our legitimate interest to use CCTV in and around some of our buildings and also to share your data (including your image) internally on the staff database.

Where we use your data to provide a reference, or for publicity reasons, we will only do so with your explicit Consent.

Special category data

Some data is considered ‘Special Category’ because it is more sensitive and requires more protection. Special category data includes information about an individual’s: race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health and sexual orientation.

Thames Reach may gather the following special category data:

– information about a medical or health condition, including whether or not you have a disability
– details of trade union membership
– information about your ethnic origin, sexual orientation, history of homelessness, health and religion or belief

This information is collected under our official capacity as your employer and is used to meet our legal obligations, for example, making reasonable adjustments or is processed as part of our contract monitoring requirements, e.g. equal opportunities.


Thames Reach takes the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed.

Your information will mainly be shared internally, including with members of the Human Resources team, your line manager and managers in the business area in which you work.

Where we engage third parties to process personal data on our behalf, for example payroll and IT, they do so on the basis of written instructions provided by us. They are under a duty of confidentiality and are obliged to implement appropriate technical and organisational security measures.

Thames Reach will not transfer your employee data to countries outside the European Union.

For how long does the organisation keep data?

Thames Reach will hold your personal data for the duration of your employment or in compliance with statutory retention periods.

Your rights

Thames Reach recognises that your personal data belongs to you and we would not wish to use it in ways the law does not allow us to. Under the General Data Protection regulations, you can exercise a variety of rights regarding our use of your data. For more information on the rights of individuals, please click here.

What if you do not provide us with your personal data?

You have some obligations under your employment contract to provide Thames Reach with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide the organisation with data in order to exercise your statutory rights, such as statutory leave entitlements. You will also have to provide Thames Reach with certain information pertaining to your right to work in the UK and payment details.

Failing to provide such data may mean that you are unable to exercise your statutory rights or may prevent Thames Reach from making you an offer of employment.