Privacy & Cookies

Privacy Statement

The Gangmasters and Labour Abuse Authority (GLAA) is the Controller for the personal data that is provided to us by you and is committed to protecting your privacy and the security of your personal data and information. Contact details for the Controller and Data Protection Officer are at the bottom of this statement.

This Privacy Policy was last updated in August 2024.

Purposes for collecting and processing your personal data

The GLAA process personal data for the purposes of Gangmasters Licensing and in line with our statutory functions and strategic objectives, to prevent worker exploitation, protect vulnerable people, ensure that licensed Gangmasters operate within the law and target, manage and where necessary investigate unlicensed / criminal activity.

In addition, the GLAA process personal data for management purposes such as Finance and Human Resources. A separate Privacy Policy for HR including Recruitment and Employment will apply. Personal data that has been anonymised is used for Performance Monitoring, Research and Development.

The GLAA collect personal data about you when you use our website for general and licensing enquiries, subscribe for updates, licence applications via our on-line application process, interacting with us via social media or when you contact us offline such as by telephone, SMS, email or post. We will only use your personal data to (i) provide the information or service you have requested; (ii) to process your enquiry; and (iii) as permitted or required by law.

The personal data you provide to the GLAA will be processed in accordance with the principles of the UK Data Protection Act 2018 including Part 3, Law Enforcement Processing and the General Data Protection Regulations (GDPR). The GLAA is a ‘competent authority’ for the purpose of Law Enforcement processing.

The information and personal data you provide in relation to Gangmasters Licensing is required under the Gangmasters (Licensing) Act 2004 and is processed for the purpose of assessing your application and managing your licence when granted. Failure to provide the correct and necessary information will delay your application. We will collect your information when you only partially complete and/or abandon any personal data and information you have inputted into our on-line application process to enquire with you regarding completion or confirm licence requirements. Your personal data will be retained for the licence application and management process and thereafter for only as long as necessary and in line with our retention policy and legal requirements.

Your personal data may be checked with other government departments, authorities and agencies plus overseas agencies who have the legal right to access and receive information held by the GLAA and to also provide to us relevant information. The GLAA Licence Application Form Guidance provides a detailed explanation of the information and personal data that the GLAA require you to provide.

Legal basis

The legal basis for processing the personal data under the Data Protection legislation is where the processing is necessary:

for law enforcement purposes,
for the performance of a task carried out for that purpose by a competent authority,
for compliance with a legal obligation,
for the performance of a contract,
for the protection individuals vital interests and safety,
where you have provided consent.
legitimate interests.

Where we use your consent to process your personal information, you do have the right to remove it at any time. Please contact the Data Protection Officer using the contact details at the bottom of this statement.

Personal data – rights

You have a right of access to your personal data (subject access) and also the right to have your personal data rectified, erased or its processing restricted if it is incorrect. Some exemptions do however apply. The right to data portability is unlikely to apply to the processing carried out by the GLAA. No decisions about you are made solely by the use of automated decision making or profiling.

To make a subject access request or exercise any of your other rights or would like to ask a question about them then please contact the Data Protection Officer using the contact details below.

Security and storage

The GLAA takes the security of all personal data very seriously and will process your personal data and information securely by using suitable technical and organisational controls to prevent unauthorised processing and against accidental loss, misuse, destruction or damage. Your personal data is only accessed and used by staff in the performance of their duties.

The GLAA does use authorised processors to process personal data on its behalf. The GLAA ensures that any such processing only takes place under contract with the correct security and compliance measures in place to ensure that your privacy and data protection rights continue to be protected. The GLAA undertake due diligence and audits with its authorised processors.

www.gla.gov.uk

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Essential cookies

We also use those that are strictly necessary for the purpose of maintaining an anonymised user session and prevent for example, unauthorised content being posted to the site. These cookies expire when you close your browser.

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Google Analytics software collects information about how you use the site. This is done to help make sure the site is meeting the needs of its users and to help make improvements.

Google Analytics stores information about:

the pages you visit - how long you spend on each page
how you got to the site
what you click on while you're visiting the site

We don't collect or store your personal information (e.g. your name or address) so this information can't be used to identify who you are.

Google isn't allowed to use or share our analytics data.

The following cookies are used:

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Apart from Google Analytics, the third party cookies collected are by:

Vimeo, which is used for streaming videos. You will receive a Vimeo cookie if you click to view one of our videos.

You Tube, which is used for streaming videos. You will receive a YouTube cookie if you click on one of YouTube videos.

Twitter is used for sharing our social media feeds. You will receive a twitter cookie if you visit Twitter from our site.

Facebook is used for sharing our social media content. You will receive a Facebook cookie if you visit Facebook from our site.

LinkedIn is used for sharing our social media content. You will receive a LinkedIn cookie if you visit LinkedIn from our site.

We do not control the setting of third-party cookies and if you require more information you should check the policy on the third-party website.

If the settings on your browser software are adjusted to accept cookies then we will assume that you are happy with this. If you wish to restrict or block these cookies you can disable them in your browser, but in doing so it may affect the functionality of our website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit https://www.gov.uk/help/cookies.

Complaints

You have the right to make a complaint in relation to the processing of your personal data. Please contact the GLAA Data Protection Officer in the first instance and we will try to resolve the matter although you do have the right to go directly to the Information Commissioner’s Office (ICO). They can be contacted at www.ico.org.uk

The Data Protection Officer for the GLAA can be contacted at the following address:

Gangmasters and Labour Abuse Authority PO Box 10272 Nottingham NG2 9PB

Email: dp@gla.gov.uk

Telephone: 0345 602 5020

1. GLAA HUMAN RESOURCES PRIVACY POLICY (Updated 8 August 2023)

This Human Resources Privacy Policy applies to both recruitment and employment.

1.1 Controller

The Gangmasters and Labour Abuse Authority (GLAA) is the Controller for the personal data that is provided to us by you. Contact details for the Data Protection Officer are at the bottom of this statement.

2. WHAT PERSONAL DATA DOES THE GLAA HR DEPARTMENT COLLECT?

2.1 GLAA Recruitment Stage

At the recruitment stage, the GLAA collects a range of information about you. This includes, but is not restricted to:

• your name, address and contact details, including email address and telephone numbers
• details of your qualifications, skills, experience and employment history
• whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process
• information about your entitlement to work in the UK
• equal opportunities monitoring information, including information about your protected characteristics (age, disability, sex, gender reassignment, pregnancy and maternity, race, sexual orientation, religion or belief, and marriage and civil partnership). This information is anonymised and does not identify you.

The GLAA collects this information in a variety of ways. For example, personal data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

The GLAA may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers, occupational health assessments and criminal records checks. The GLAA will only seek information from third parties once a job offer to you has been made and will inform you that it is doing so.

2.2 GLAA Employment

As an employee, the GLAA collects and processes additional information about you in addition to that which has been collected at the recruitment stage. This includes, but is not restricted to:

• your name, address and contact details, including email address and telephone number, date of birth and gender identity
• the terms and conditions of your employment
• details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with the organisation
• information about your remuneration, including entitlement to benefits such as pensions or insurance cover
• details of your bank account and national insurance number
• information about your marital status, next of kin, dependants and emergency contacts
• information about your nationality and entitlement to work in the UK
• information from criminal records checks and driving licence checks
• details of your contractual working arrangements and attendance at work
• details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals, and the reasons for the leave
• details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence
• assessments of your performance, including performance reviews and ratings, training you have participated in, performance improvement plans and related correspondence
• information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments
• details of any trade union membership that you have provided
• equal opportunities monitoring information, including information about your Protected Characteristics (age, disability, sex, gender reassignment, pregnancy and maternity, race, sexual orientation, religion or belief, and marriage and civil partnership).

Personal data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including secure email).

3. WHY DOES THE GLAA HR DEPARTMENT PROCESS PERSONAL DATA?

3.1 GLAA Recruitment Stage

At the recruitment stage, the GLAA needs to process data to take steps at your request prior to entering into a contract with you. Should you be successful in your application, and an offer is made and accepted, the GLAA also needs to process your personal data to enter into a contract with you.

In some cases, the GLAA needs to process your personal data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.
The organisation has a legitimate interest in processing your personal data during the recruitment process and for keeping records of the process.

Processing personal data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. The organisation may also need to process personal data from job applicants to respond to and defend against legal claims.

The GLAA processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have advised they have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

The GLAA will process anonymised information where you have chosen to provide it such as information about your Protected Characteristics (age, disability, sex, gender reassignment, pregnancy and maternity, race, sexual orientation, religion or belief, and marriage and civil partnership). This information is anonymised and does not identify you. This is for equal opportunities monitoring purposes.

Should you be successful and are offered a position, the GLAA will require you to provide a ‘basic level check’ in relation to criminal convictions and offences. This can be obtained from the Disclosure and Barring Service. Where the GLAA seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

The GLAA will not use your data for any purpose other than the recruitment exercise for which you have applied. If you are successful in your application, and we enter into an employment contract with you, you will be required at that stage to provide information necessary to facilitate the employment relationship.

3.2 GLAA Employment

Once employed, the GLAA needs to process your personal data to enter into an employment contract with you and to meet its legal obligations under your employment contract. For example, the GLAA needs to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer other applicable benefit, pension and insurance entitlements.

In addition, the GLAA is required to check an employee's entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled.

For all roles, the GLAA will require you to provide an up to date ‘basic level check’ in relation to criminal convictions and offences. This can be obtained from the Disclosure and Barring Service. In some cases, additional vetting may be required. Where the GLAA seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

The GLAA has a legal obligation and legitimate interest in processing your personal data before, during and after the end of the employment relationship. Processing employee personal data allows the GLAA to:

• complete recruitment and promotion processes
• maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights
• operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the GLAA
• operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes
• operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled
• obtain occupational health advice, to ensure that the GLAA complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled
• operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that the GLAA complies with its duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled
• ensure effective general HR and business administration
• provide references upon request for current or former employees
• respond to and defend against legal claims
• monitor and promote equality within the GLAA

Some special categories of personal data, such as information about health or medical conditions including disabilities, is processed by the GLAA to meet its obligations with regard to employment and health and safety law.

4. PROVISION OF PERSONAL DATA

You are under no statutory or contractual obligation to provide personal data to the GLAA during the recruitment process. However, if you do not provide necessary and relevant information, the GLAA may not be able to process your application properly or at all.

Once you are employed by the GLAA you have some obligations under your employment contract to provide necessary and relevant personal data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters.

You may also have to provide the organisation with personal data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you will be unable to exercise your statutory rights.

Certain personal data and information, such as contact details, your right to work in the UK and payment details, have to be provided to enable the GLAA to enter a contract of employment with you. If you do not provide other necessary and relevant information, this will hinder the GLAA's ability to administer the rights and obligations arising as a result of the employment relationship effectively.

5. WHO HAS ACCESS TO PERSONAL DATA?

5.1 GLAA Recruitment Stage

At the recruitment stage your personal data will be accessed and processed internally by GLAA staff for the purpose of the application and recruitment exercise. This includes members of the People and Change team, interviewers involved in the recruitment process, managers in the business area with the vacancy and IT staff if access to the personal data is necessary for the essential performance of their roles.

The GLAA will not disclose your personal data to third parties, unless your application for employment is successful and an offer of employment is made. The GLAA will then process your personal data and use it for example to make contact with former employers to obtain references for you.

The GLAA will not transfer your personal data outside of the UK.

5.2 GLAA Employment Stage

Relevant aspects of your personal data will be accessed and processed internally by GLAA staff for the purpose of managing your employment. This includes members of the People and Change team, Finance and IT team, your line manager, managers in the business area in which you work if access to the data is necessary for the essential performance of their roles.
The GLAA also provides your personal data to authorised third parties that process personal data on its behalf, for example in connection of occupational health services.

The GLAA will not transfer your personal data outside of the UK.

6. HOW DOES THE GLAA PROTECT PERSONAL DATA?

The GLAA takes the privacy and security of your personal data seriously. The GLAA has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.

Where the GLAA engages third parties to process personal data, for example, pension contributions, on its behalf, it does so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of the personal data.

In addition, the GLAA carry out due diligence and audits on its suppliers where necessary.

7. FOR HOW LONG DOES THE GLAA RETAIN PERSONAL DATA?

If your application for employment is unsuccessful, the GLAA will hold your personal data on file for one year after the end of the relevant recruitment process. If you agree to allow the GLAA to keep your personal data on file, the organisation will hold your data on file for consideration for future employment opportunities. At the end of that of the one year period (following the unsuccessful application), or once you withdraw your consent, your personal data is securely deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and processed for the duration of your employment and afterwards in line with the GLAA retention policy.

8. YOUR RIGHTS

You have a number of rights in relation to the processing of your personal data:

• access and obtain a copy of your personal data
• rectify incorrect or incomplete data
• erasure
• restriction
• data portability
• objection
• automated decision making, including profiling.

If you would like to exercise any of these rights, please contact the GLAA Data Protection Officer.

9. CONTACT

The Data Protection Officer for the GLAA can be contacted at the following address:

Gangmasters and Labour Abuse Authority
PO Box 10272
Nottingham
NG2 9PB
Email: dp@gla.gov.uk
Telephone: 07795 286414

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1. GLAA HUMAN RESOURCES PRIVACY POLICY (Updated 8 August 2023)