Privacy Notice-
Employee and Applicant Privacy Statement
Effective 17th December 2025
Background:
At Plymouth Community Homes (PCH) we are committed to ensuring that your privacy is protected, and that data is used in accordance with the current data protection legislation in force in England and Wales.
This privacy notice sets out when we collect data from you, why we collect personal information from you, how we use it and who we may share it with. It also explains your individual rights under the current data protection legislation.
If we ask you to provide information which can identify you, then we will only use it in accordance with this privacy notice.
This privacy notice is designed to be clear and concise. It does not cover every detail of how PCH collects and uses personal information. If you require further information or an explanation on any aspect, we are happy to assist. Any queries regarding this notice and our privacy practices can be sent to the company Data Protection Officer by email using governance@plymouthcommunityhomes.co.uk or by writing to the Head of Governance, who is also the Data Protection Officer at -
Plymouth Community Homes
Plumer House
Tailyour Road
Crownhill
Plymouth
PL6 5DH
Alternatively, you can contact the People and Culture team via HR@plymouthcommunityhomes.co.uk .
Who we are.
Plymouth Community Homes Limited is a registered housing provider. Our registration number is 30637R. Our registered office is Plumer House, Tailyour Road, Crownhill Plymouth, PL6 5DH
For the purposes of data protection legislation, Plymouth Community Homes Limited is a Data Controller
Why we collect information
We collect and process your personal information to support you throughout your journey with PCH – from recruitment and onboarding through to your employment.
Our lawful basis for this processing is the performance of your employment contract. It enables us to fulfil our contractual and legal obligations to manage your recruitment, onboarding, and ongoing employment effectively and ensure you receive the services and benefits you expect.
Typical examples include payroll details, pension information, information to verify your eligibility to work in the UK and the data we need to set you up during onboarding
At the applicant stage we process the personal data you provide, as well as information collected from external sources (such as references, assessments, and relevant social media profiles), for the legitimate purpose of assessing your suitability for vacant positions.
We also use this data to analyse recruitment trends to improve our hiring processes.
We may also process your information to comply with legal obligations, such as maintaining records and reasons of absence and other statutory leave entitlements, and meeting health and safety requirements. Occasionally, we may need to obtain occupational health reports where necessary to assess your working capacity.
Additionally, PCH processes personal data where required to establish, exercise, or defend legal claims, and to protect the organisation.
Sometimes, we process data based on PCH’s legitimate business interests, as defined under the Data Protection Act. For example, the use of CCTV footage and door access control data to maintain security.
Finally, we ensure data accuracy and integrity in line with the legislation accountability and record-keeping requirements.
Special categories of personal data (for example, health data or trade union membership, where relevant to the role) are processed only where necessary to fulfil legal obligations and/or exercise specific rights under employment, social security, and social protection law.
You may also choose to join our Talent Pool, which allows us to notify you of future vacancies that match your profile. If you are successful and are made a conditional offer of employment, we will conduct pre-employment checks, including background checks.
What information do we collect:
At Applicant Stage:
We need to inform you about your privacy rights when using the PCH Applicant Tracking System (ATS) and, if you are successful in gaining employment, our People and Culture Digital System.
To apply for a position online with PCH, you will need to create and register a profile on our ATS by creating a username and password of your choice. Your username and password will be required to gain access to your profile. You can also create a profile without applying for a specific position or without releasing your profile into the candidate pool.
We collect personal data from you so that we can assess your suitability for employment with us and conduct our statistical analysis, such as (but not limited to):
· Name, address, email, telephone number, NI Number
· Date of Birth
· Employment and work experience Background, education, grades and references etc
· CV (if applicable)
· Professional Membership
· Equal opportunities monitoring information (defined as special category data) - this information is purely for statistical analysis and monitoring purposes
· Answers to application questions
· Any other information you wish to provide in support of your application
· Where applicable Rehabilitation of Offenders & criminal records
· Assessment / Test results
· LinkedIn and other relevant social media profiles
At a Conditional Offer Stage:
If you are successful at recruitment, we will gather further information from you so that we can move you into the next stage of your journey with PCH.
Once you have been issued with a conditional offer, we will upload your details to our HR system, and will collect:
· Reference checks e.g. from former employers
· Criminal record checks
· Financial information (e.g. bank account number, salaries, debts, social benefits, pension, credit report)
· Special categories of personal data (e.g. health data or your union memberships, where legally permitted and if relevant for the specific position)
As an employee, you will sign a contract of employment and agree to additional terms on how your data is managed and stored.
During your employment:
During your employment with PCH, in addition to the above data collected at applicant and offer stage, we will collect and store securely the following, including but not limited to:
· Performance management information such as appraisal records and 121 supervision notes
· Disciplinary, grievance and performance management records including any warnings issued and related correspondence
· Learning and Development information
· Next of Kin /emergency contact details here is a separate privacy notice for emergency contacts
· Health information – including learning needs and disability information and whether reasonable adjustments need to be made
· Occupational health and health surveillance records
· Pay records, including expenses, allowances and bonus payments
· Tax and pension information
· Driving licence summary
· Copy of business car insurance
· Attachment of earnings information
· Security identification photograph
· General marketing and publicity photographs –events and community use
· CCTV video footage
· Door access controls data
· System use and activity logs collected under PCH’s Information Security Policy (to ensure compliance and protect IT systems)
· Location tracking information for lone workers
· Fleet vehicle driver tracking information
· Declarations of Interest
· Trade Union membership
· Criminal convictions and offences
· We may also provide information to external organisations to administer employee benefits such as pension, childcare vouchers, cycle to work schemes etc.
We may also receive information about you from third parties including:
· Your Referees
· HMRC
· Our Occupational Health provider
· Child Benefit Agency
· Your Pension provider
· Court orders – attachment of earnings
· Trade Union membership
· Organisations that provide learning and development
· Credit reference agencies
What we do with your data?
PCH needs to process certain personal data about our employees for administrative and management purposes such as:
· Managing Human Resources processes such as recruitment, payment of salaries and pensions, performance management, disciplinary and grievance processes and training and development
· Providing facilities such as IT services
· Health and Safety reporting
· As part of an agreement, such as a post entry training loan agreement or salary sacrifice scheme
· Monitoring Fleet vehicle usage through vehicle tracking devices
· Dealing with insurance claims
· Monitoring equal opportunities
· Building Security such as using CCTV and access controls
· Photographic ID Cards to identify employees to customers
· Provision of well-being and support services, e.g., Occupational Health
· Compliance with legal obligations such as making external/statutory returns to HMRC or attachment of earnings
· Health and wellbeing programmes
· Maintaining contact with past employees
· Report and monitor data relating to protected characteristics to inform and develop action plans to promote equality, diversity and inclusion
· Provide information to external organisations to administer employee benefits such as childcare vouchers, cycle to work schemes etc.
· Manage joint contract of employment / external secondments which require information to be shared with a host employer
We also collect your data for statistical analysis and to integrate into or out of our People and payroll systems and other PCH systems.
How can you access the information we hold about you?
You can log into your account at any time to review, update, or amend the personal information you have provided. You may also withdraw your details whenever you choose. All requests to access or change information will be handled in accordance with applicable legal requirements.
Personal data may be shared internally with colleagues who legitimately need it to perform their duties. The amount of personal information shared within PCH will be limited to what is reasonably necessary and, where possible, anonymised without compromising its purpose.
Employee data may also be analysed for management and planning purposes, such as retirement forecasting.
Additionally, our Business Continuity plans include the personal contact details of key employees. This is done in pursuit of our legitimate interests to ensure they can be contacted if plans need to be activated outside normal working hours.
CCTV & Recordings
We operate a CCTV/sound recording system at Plumer House in pursuit of our legitimate interests of building security and the detection and prevention of crime.
There are also CCTV cameras in use at The Beacon, Brest Road Stores and the ReUse Centre at Burrington Way. This is for site security purposes and to track employee movements. For more information refer to the separate Privacy Notice for CCTV and Door /Barrier Access control at Plumer House, The Beacon & Brest Road.
We operate CCTV / sound recording in and around some properties in pursuit of our legitimate interests to provide a safe and secure environment for residents and to protect the general interests and well-being of all building users. If you are visiting those properties your image may be captured. For more information refer to the separate Privacy Notice for Tenants.
Employee photographs are used on PCH identity cards for the purposes of identification and security. ID cards are required for access to Plumer House and its car park for building security. This access data may also be used for monitoring purposes including tracking employee movements.
Employee photographs are used on PCH employee emails (Outlook) for the purposes of identification and security.
Telephone calls and virtual meetings / training events (Teams, Zoom etc) - recordings of calls and virtual meetings may be used in pursuit of our legitimate interests, for the following reasons:
· For employee training to develop confidence and potential of employees and to improve services.
· To check and measure whether we meet standards agreed with customers.
· For use in appraisals with employees to develop better customer service.
· As evidence where there are disputes.
· As evidence in investigations concerning either our customers or employees.
Access to call recordings is through sampling apart from training purposes or when abusive or threatening behaviour has occurred, or a complaint has been made and requires investigation.
Access to recordings of virtual meetings / training events are accessed by participant electronically following the event. Attendees will be informed during the meeting / training that the event is being recorded.
PCH monitors and records usage of IT services and applications to ensure adherence to PCH Information Security Policy and the IT Usage Policy. This information may be provided to PCH Senior Managers in the event of non- compliance with this policy.
Special Category Information
PCH also has a legitimate interest in processing special category data where necessary, to fulfil legal obligations and exercise specific rights under employment law, or when required to assess an individual’s working capacity. This includes:
· Managing People and Culture processes such as administering Sick Pay and Sick Leave schemes, managing absence, administering Maternity Leave and related pay schemes, managing retirement etc.
· In disciplinary and grievance cases where the information is strictly relevant to achieving a fair outcome.
· Managing a safe environment and ensuring fitness for work
· Assessing employees’ working capacity
· Managing obligations under Equal Opportunities legislation
· Provision of occupational health and wellbeing services to individuals
· Establishing, exercising and defending legal claims
· Equality & Diversity monitoring
· Protecting the vital interests of the employee or another person
PCH will obtain information about past criminal convictions / offences as a condition of employment for certain posts.
How long do we store your information?
We will only store your information for as long as necessary to fulfil its purpose and meet legal obligations.
For recruitment purposes, if you have not been success in appointment, your personal data will be stored for 12 calendar months from the date of registration, after which it will be securely deleted unless you renew your consent for us to retain it. You may delete your information at any time via your online account.
In most cases, this means a maximum of 7 years after you leave PCH employment, unless you are a member of the LGPS scheme, in which case the retention period is 13 years.
Medical records relating to exposure of hazardous substances including the control of asbestos will be stored for 40 years in compliance with the Control of Asbestos Regulations 2012. For more information, please refer to the Data Retention Schedule.
If you are involved in a dispute with PCH, your information will be stored until all legal proceedings have concluded.
Specific retention periods include:
· CCTV footage: kept for a period of 28 days unless the footage is being used to investigate an alleged crime or incident in which case it may be retained for up to 2 years following the conclusion of any investigation.
· Door access control data: up to 42 months.
· Vehicle tracking data: retained for 1 year, then archived for 7 years.
These retention periods are documented in the PCH Data Retention Schedule, available in Policies and Strategies on the Intranet. All information will be securely disposed of at the end of its retention period.
Sharing your information with third parties
We will not share your personal information with anyone who claims to represent you unless we are satisfied that you have appointed them, or they are acting in a recognised official capacity. We do not give out to information to other employees requesting your personal information (for example your address or data of birth) unless there is a legitimate business reason for doing so.
We may share your personal information but will only do so when this is fair and we have a lawful basis for doing so. In some circumstances we are legally obliged to share information. We do not rely on your consent to share your data, unless we specifically ask for it. Reasons for sharing your data include:
· to comply with the law (e.g., police, health authorities etc.)
· to seek legal advice or in connection with court proceedings or other statutory action
· where there is a clear health and safety risk to yourself or others
· if there are child protection and safeguarding issues
· where there is a clear risk to building users
· for the detection and prevention of crime, prosecution of offenders and for the detection and prevention of fraud
· where you have provided consent
PCH may need to share your personal and special category personal data with third parties outside of PCH who are contracted to work on its behalf, for example:
· Your Pensions provider
· Occupational Health,
· Insurers
· Consultants including for example obtaining legal and pensions advice.
· Auditors undertaking investigations or carrying out periodic reviews.
· HMRC
· Child Benefit Agency /DWP
· Mortgage reference/Letting agencies
· Trade Unions
· Childcare or cycle to work organisations as part of a Salary sacrifice scheme
· Organisations that provide learning and development
· Organisations that may issue an attachment of earnings
· The Police
· Criminal records information through the Disclosure and Barring service for applicable posts
· ACAS and employment tribunal services if necessary to defend employment claims
· IT and cloud service providers that process data on PCH’s behalf
· Vehicle tracking data from PCH fleet vehicles is stored on a secure hosted platform. This data includes personal information and is used solely to manage fleet operations. In some cases, other IT data may be used for testing purposes outside PCH, under contractual agreements that ensure appropriate data protection.
Lone worker tracking data is also held on a hosted digital platform. This includes contact details for emergency escalation and is used exclusively to respond in an emergency or urgent situations. Our contract with host service providers always includes strict safeguards to protect your data.
PCH will, on request, confirm dates and nature of your employment to a prospective employer if you have identified us as a referee. We will also provide salary /employment information to mortgage or letting agencies where you have given consent for us to do so.
Security
We have implemented robust technical and organisational measures to safeguard personal data against unauthorised access, disclosure, or loss, in accordance with current data protection legislation.
Your responsibility
You are responsible for checking that any personal data you provide PCH is accurate and up to date. You must inform PCH of any changes to your data (e.g., change of name or address). You can change this directly on the relevant Self-Service IT system. If in doubt, please refer to the People & Culture team. You are required to inform anyone whose contact details you have provided to PCH for contacting in the case of an emergency that the information is being held and to ensure they agree. You should hand them a copy of the Emergency Contact Details Privacy Notice which will be given to you and can also be located on the Intranet.
Under your employment contract, you are required to provide PCH certain personal data. This includes reporting absences and, where necessary, supplying information related to disciplinary or other matters under the implied duty of good faith. You may also need to provide data to exercise your statutory rights, such as entitlement to statutory leave. Failure to provide this information may mean that you are unable to exercise your statutory rights.
Certain information, such as your contact information, proof of your right to work in the UK, and payment details, are essential for us to enter into and maintain your employment contract with us. If you do not provide requested information, it may hinder PCH’s ability to manage the rights and obligations arising from the employment relationship effectively.
Your Rights in relation to your personal data
In certain circumstances, data protection legislation gives you a number of individual rights in relation to your personal data. These are as follows:
· The Right to be Informed about how your data is managed – this right is met by this privacy notice and a range of other notices which relate to specific aspects of PCH, such as the CCTV privacy notice and the website privacy notice.
· The Right of Access to your personal information so that you can be aware of and verify what personal data we hold. Click here for details on how to apply for this right or ask the governance team for more information.
· The Right of Rectification - to have any personal data corrected if it is inaccurate, incomplete or out of date.
· The Right of Erasure of your personal data – this only applies in certain circumstances, such as where you have given consent for us to hold information and you withdraw that consent.
· The Right to restrict processing – in certain circumstances you have the right to block or restrict how we process your data.
· The Right to data portability – which in certain circumstances allows you to obtain and reuse your personal data for your own purposes across different services
· The Right to object - in certain circumstances, to the processing of personal data.
· The Right not to be subject to automated decision making – PCH does not do this
· The Right to Complain - about how your personal data is handled. If you wish to make a complaint, the section below provides more information.
More information on the individual rights and how they apply can be obtained by clicking here, or you can visit the ICO website (ico.org.uk)
If you wish to exercise any of the above rights, please contact:
Governance Team
Plymouth Community Homes
Plumer House, Tailyour Road, Crownhill, Plymouth, PL6 5DH
Alternatively, you can make a request electronically, by email, to governance@plymouthcommunityhomes.co.uk. or telephone the Governance Team on
0808 230 6500.
Making a complaint
If you believe that PCH has not handled your personal information correctly you have the right to make a complaint. You can raise a complaint in a number of different ways:
· To your manager
· To your Head of Service
· To the Head of Governance (Data Protection Officer)
· To the Head of People and Culture
You also have the right to complain to the Supervisory Authority (ICO at ico.org.uk) about our data processing activities.
You can contact the Information Commissioner’s Office (ICO) at:
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
Legal Status:
Plymouth Community Homes Ltd is a registered society under the Co-operative and Community Benefit Societies Act 2014 (which consolidates the Industrial and Provident Societies Acts) and is registered with the Financial Conduct Authority (registration 30637R) and the Regulator of Social Housing (registration L4543).
At the time of issuing this Notice, Plymouth Community Homes Ltd has two wholly owned subsidiaries, Plymouth Community Homes Regeneration Company Ltd (PCHR), company number 7272688 and Plymouth Community Homes Energy Ltd (PCHE), company number 8028170. Both subsidiaries are incorporated under the Companies Act 2006.
