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Privacy Policy


Employee Privacy Notice:

Data controller:               Pure Human Resources Ltd, Suite 4, Kingfisher House, Rownhams Lane, North Baddesley, Hampshire, SO52 9LP

As a data controller, Pure Human Resources Ltd (we, us, our) is responsible for deciding how we hold and use personal data about you, and we collect and process personal data relating to employees in order to manage the employment relationship. We are committed to being transparent about how and why we collect and use this data, and to meeting our data protection obligations. You are being provided with a copy of this privacy notice, which includes information that must be provided under the EU General Data Protection Regulation, to make you aware of how and why we collect and process your personal data both during and after your working relationship with Pure Human Resources Ltd and should be read in conjunction with Pure Human Resources Ltd.’s Data Protection policy.

This applies to all employees, workers and contractors. Job applicants should instead read our Applicant Privacy Notice.

What data does Pure Human Resources Ltd collect?

Pure Human Resources Ltd will collect, process and store a range of data about you. This includes:

  • your name, address and contact details, including email address and telephone number, date of birth, gender and car registration number;
  • information relating to the terms and conditions of your employment;
  • information collected during the recruitment process, including CV/application form, references from previous employers, interview notes, copies of certificates or membership of professional bodies and any pre-employment assessments;
  • details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with us, including training records;
  • information about your remuneration, including entitlement to benefits such as pensions, healthcare, death in service or other benefits;
  • details of your bank account, information relating to tax status, tax code and National Insurance number;
  • information about your marital status, next of kin, dependents and emergency contacts;
  • information about your nationality, immigration status and entitlement to work in the UK;
  • images, including CCTV images, photographs and videos, or photographic ID;
  • information relating to your ability to drive (where relevant);
  • information regarding your use of our IT systems, including usage of telephones, email, PDAs and the internet;
  • data relating to movement whilst driving a Company vehicle;
  • details of your schedule (days of work and working hours) and attendance at work, including clocking in records;
  • details of periods of leave taken by you, including the type and reasons for the leave, and any related correspondence;
  • details of any disciplinary or grievance procedures, or investigations in which you have been involved, including any warnings issued to you and related correspondence;
  • assessments of your performance, including appraisals, performance reviews and ratings, performance improvement plans and related correspondence;
  • any termination of employment or engagement documents, including resignation letters, dismissal letters, redundancy letters, minutes of meetings, settlement agreements and any related correspondence; and
  • any other category of personal data which we may notify you of from time to time.

Pure Human Resources Ltd may also collect, process and store the following special categories of your personal data:

  • information about medical or health conditions, including name and address of GP, sickness absence records, GP/Occupational Health reports and whether or not you have a disability for which we need to make reasonable adjustments;
  • information about your criminal record; and
  • information about your racial or ethnic origin.

This information may be collected in a variety of ways, for example, during the recruitment process, either directly from you or from a third party such as a recruitment agency. We may also collect personal data about you from other external third parties, such as references from former employers and information from the Disclosure and Barring Service (DBS) relating to any criminal convictions.

We will also collect additional information throughout the period of your working relationship with Pure Human Resources Ltd, which may be collected in the course of your work-related activities or through meetings or other correspondence. Some information is mandatory and/or is a statutory or contractual requirement and some of it you may be asked to provide on a voluntary basis. We will inform you whether you have a choice to provide it or not.

Data will be stored in a range of different places, including in your personnel file, in HR management systems and on other IT systems (including our email system).

Why does Pure Human Resources Ltd process personal data?

We need to process data to enter into an employment contract with you and to meet our obligations under your employment contract. For example, we need to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer benefits, such as a pension.

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are 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.

In other cases, we have a legitimate interest in processing personal data before, during and after the end of the employment relationship, providing that your interests or your fundamental rights do not override our interests. Processing employee data allows us to:

  • run 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 and employment terms;
  • comply with statutory and/or regulatory requirements and obligations, for example, checking your right to work in the UK;
  • ensure that employees are paid correctly and receive the correct benefits to which they are entitled, including any payment of contractual sick pay, SSP, SMP, SPP, SAP or ShPP;
  • operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
  • operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes;
  • record and assess your education, training and development activities and needs;
  • to make decisions about continued employment or promotion;
  • operate and keep a record of absence and absence management procedures and to allow effective workforce management;
  • obtain occupational health advice, to ensure that we comply with duties in relation to individuals with disabilities and meet our obligations under health and safety laws;
  • 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 we comply with 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;
  • monitor your use of our IT systems to ensure compliance with our IT-related policies, as well as ensuring adherence to any other Company rules, policies and procedures;
  • prevent fraud;
  • provide references on request for current or former employees; and
  • respond to and defend against possible legal claims.

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

Why does Pure Human Resources Ltd collect and process sensitive personal data?

Some special categories of personal data, such as information about health or medical conditions or information about criminal convictions, is processed to carry out employment law obligations (such as those in relation to employees with disabilities). Information about health or medical conditions is also processed for the purpose of establishing the working capacity of an employee.

We may also process these special categories of personal data where we have your explicit written consent, in which case, we will provide you with full details of the information that we would like and the reason for our request, so that you can consider whether you wish to consent or not.

The purpose for Pure Human Resources Ltd processing these special categories of personal data are to:

  • assess your suitability for employment or promotion;
  • comply with statutory and/or regulatory requirements and obligations, for example, carrying out criminal record checks;
  • comply with our duty to make reasonable adjustments for employees with disabilities;
  • administer the contract that we have entered into with you;
  • operate and maintain a record of sickness absence procedures; and
  • establish your fitness to work.

Where we process other special categories of personal data, such as information about ethnic origin, this is done for the purposes of equal opportunities monitoring. Data that we use for these purposes is anonymised or is collected with the express consent of employees, which can be withdrawn at any time. Employees are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

We do not need your consent to process special categories of personal data when we are processing it for the following purposes, which we may do:

  • where it is necessary for carrying out rights and obligations under employment law;
  • where it is necessary to protect your vital interests or those of another person where you/they are physically or legally incapable of giving consent;
  • where you have made the data public;
  • where processing is necessary for the establishment, exercise or defence of legal claims; and
  • where processing is necessary for the purposes of occupational medicine or for the assessment of your working capacity.

Who has access to data?

Your information may be shared internally, including with members of the HR and recruitment team, your line manager, managers in the business area in which you work and IT staff if access to the data is necessary for performance of their roles.

Pure Human Resources Ltd will share your data with specific third party data processors who provide a service to us and process data on our behalf (further information given below) however we have contracts in place and any third party is only permitted to process your personal data for our specified purposes and held in accordance with our instructions.

We will also share your data with previous employers, in order to obtain pre-employment references.

We may share your data with third parties such as those that provide professional services such as specialist employment law guidance or external auditors, or where it is necessary to administer the contract that we have entered into with you or where we need to comply with a legal obligation (e.g. detection and prevention of crime). We may also share your data with third parties in the context of a sale of some or all of our business, or in a TUPE situation. In those circumstances, the data will be subject to confidentiality arrangements.

It may also be necessary to share your data with a regulator, or to otherwise comply with the law.

Third party data processors

Pure Human Resources Ltd will share relevant data with the following third party data processors as necessary, who process data on our behalf. The data shared with them will be limited to that necessary for them to carry out their duties for us:

  • Xebra Accounting Fareham Limited (payroll provider)
  • Asset Management Financial Services Limited (healthcare/death in service broker)
  • Vitality Corporate Services Limited (healthcare provider)
  • Canada Life Limited (death in service provider)
  • Standard Life Assurance Limited (pension provider)
  • Affordable I.T Limited (I.T provider)
  • Next Communications & Security Limited (telephone provider)
  • Edenred Limited (childcare voucher provider)

This list is correct as of 18 May 2018 and will be reviewed regularly. We reserve the right to substitute any of these organisations as necessary and update this notice.

How does Pure Human Resources Ltd protect your data?

Pure Human Resources Ltd takes the security of your data seriously. We have internal policies and controls in place to ensure that your personal data is not lost, accidentally destroyed, misused or disclosed, and is limited to our employees or other third parties who have a need to know for the proper performance of their duties.

Where we engage third parties to process personal data on our behalf, they do 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 data.

We have a data breach policy 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.

How long does Pure Human Resources Ltd keep your data for?

We will hold your personal data for the duration of your employment and such data will be reviewed annually to ensure out of date or irrelevant data is removed/updated.

Personal information held relating to criminal record (DBS) checks will be limited to the date and type of check, the outcome and the certificate reference number (copies of certificates are not held).

Should you leave Pure Human Resources Ltd, we will streamline the personal data to ensure that only relevant data is retained, and this will be held for a period of 6 years from the end of the year in which you left our employment.

Personal information no longer required will be securely and effectively destroyed or permanently erased from our IT system, and we will also require third parties to destroy or erase such personal information where applicable. Where information has been anonymised and therefore you cannot be identified, we may retain it for a longer period.

Your rights in connection with personal data

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require the organisation to change incorrect or incomplete data;
  • require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing;
  • restrict the processing of your data should you wish to establish the accuracy of the data or the reason for processing; and
  • request the transfer of your data to another party.

If you would like to exercise any of these rights, please email who will deal with your request. Alternatively, you can write to Data Protection, Pure Human Resources Ltd, Suite 4, Kingfisher House, Rownhams Lane, North Baddesley, Hampshire, SO52 9LP.

If you believe that Pure Human Resources Ltd has not complied with your data protection rights, you can complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. Full contact details including a helpline number can be found on the ICO website (

We will not transfer your personal data outside the European Economic Area unless there are adequate measures in place that ensure a level of protection equivalent to that afforded by the Data Protection Act and GDPR.

What if you do not provide Pure Human Resources Ltd with your personal data?

You have some obligations under your employment contract to provide us 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 us with 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 are unable to exercise your statutory rights.

Certain information, such as contact details and your right to work in the UK, have to be provided to enable us to enter a Contract of Employment with you and should you choose not to provide it, we may not be able to carry out certain parts of the Contract between us. For example, if you do not provide us with your bank account details we may not be able to pay you. It might also stop us from complying with certain legal obligations and duties which we have, such as to pay the right amount of tax to HMRC or to make reasonable adjustments in relation to any disability you may suffer from.

Automated decision-making

Recruitment decisions are not based solely on automated decision-making and are taken into consideration along with any other information gathered during the recruitment process, and final decisions are made by hiring managers and members of the HR and recruitment team.


Pure Human Resources Ltd reserve the right to amend or update this privacy notice at any time and will issue you with a new privacy notice when we make significant amendments or updates. This privacy notice was last updated on 18 May 2018.


If you have any questions about this privacy notice or how we handle your personal information, please email who will deal with your request. Alternatively, you can write to Data Protection, Pure Human Resources Ltd, Suite 4, Kingfisher House, Rownhams Lane, North Baddesley, Hampshire, SO52 9LP.


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