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HR Privacy Policy

HR Privacy Policy

Radius Limited (“RADIUS”) HR PRIVACY NOTICE

Introduction

Radius Limited and our associated companies ("Radius", "we", "our" or "us") hold and process data on all current and former employees, workers, individual contractors, contingent workers, applicants, interview candidates, interns, agency workers, consultants, directors, members (i.e. partners), and third parties whose information you provide to us in connection with the employment relationship (e.g. next-of-kin, emergency contact information and/or dependents) ("staff" or "you" or "your").

We take your data protection rights and our legal obligations seriously. Your personal information will be treated in a secure and confidential manner and only as set out below.

The following Human Resources (HR) ‘Privacy Notice’ (also often referred to as a Fair Processing Notice) describes the categories of personal information we may process, how your personal information may be processed and how your privacy is safeguarded in the course of our relationship with you. It is intended to comply with our obligations to provide you with information about Radius's processing of your personal information under privacy laws. It does not form part of your contract of employment or engagement.

If you have any questions regarding the processing of your personal information or if you believe your privacy rights have been violated, please contact Radius's Data Protection Officer whose contact details are noted at the end of this HR Privacy Notice.

Processing of personal information

Radius collects and processes your personal information for the purposes described in this HR Privacy Notice. Personal information means any information describing or relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

The relevant associated company of Radius identified in your employment contract or contract for services (whether issued by Radius or a third party) will be the data controller of your personal information. In addition, where processing of personal information is undertaken by other associated companies of Radius for their own independent purposes, these associated companies may be joint controllers of your personal information.

What data do we process?

Personal Information

We may collect various types of personal information about you for the purposes described in this HR Privacy Notice including:

Staff related data: your title, forename, middle name(s) and surname, birth name, preferred name, any additional names, gender, nationality, second nationality, civil/marital status, date of birth, age, home contact details (e.g. address, telephone number, e-mail), national ID number, immigration and eligibility to work data, languages spoken; next-of-kin/dependent contact information;
Data related to your engagement with Radius: work contact details (e.g. address, telephone number, e-mail), work location, default hours, default language, time zone and currency for location, your worker ID and various system IDs, your performance review information, your work biography, your reporting line, your employee/contingent worker type, your hire/contract begin and end dates, your cost centre, your job title and job description, your working hours and patterns, whether you are full or part time; your termination/contract end date; the reason for termination; your last day of work; exit interviews, references, status (active/inactive/terminated); position title; the reason for any change in job and date of change; your benefit coverage start date;
Recruitment data: qualifications, references, CV and application, interview and assessment data, vetting and verification information;
Regulatory data: records of your registration with any applicable regulatory authority, your regulated status and any regulatory references;
Remuneration and benefits data: your remuneration information (including salary/hourly plan/contract pay information as applicable, allowance, bonus and merit plans), bank account details, grade, social security number, tax information, third party benefit recipient information;
Leave information: absence records (including dates and categories of leave/time-off), holiday dates and information related to family leave;

HR processes data: allegations, investigations and proceeding records and outcomes, colleague and manager feedback, appraisals, talent programmes, formal and informal performance management processes, flexible working processes, restructure and redundancy plans, consultation records, selection and redeployment data, health and safety audits, risk assessments, incident reports, data relating to training and development needs or training received;
Monitoring data (to the extent permitted by applicable laws): Closed Circuit television footage, system and building login and access records, keystroke, download and print records, call recordings, data caught by IT security programmes and filters; and
Employee claims, complaints and disclosures data - termination arrangements and payments, subject matter of employment based litigation and complaints, employee involvement in incident reporting and disclosures.

Certain additional information may be collected where this is necessary and permitted by local applicable laws.

Special categories of personal information

To the extent permitted by applicable laws Radius may also collect and process a limited amount of personal information falling into special categories, sometimes called “sensitive personal data”. This term includes information relating to such matters as racial or ethnic origin, religious beliefs, physical or mental health (including details of accommodations or adjustments), certain maternity/adoption information, trade union membership, sexual orientation, information regarding sexual life, biometric data, genetic data, [criminal records and information regarding criminal offences or proceedings].

How does Radius collect data?

Radius collects and records your personal information from a variety of sources, but mainly directly from you. You will usually provide this information directly to your managers or local Human Resources contact or enter it into our systems (for example, during the recruitment process, your participation in HR processes, emails you send or through verbal information which may be recorded). In addition, further information about you will come from your managers or Human Resources.

We may also obtain some information from third parties, for example, references from a previous employer, medical reports from external professionals, tax authorities, benefit providers or where we employ a third party to carry out a background check (where permitted by applicable law).

In some circumstances, data may be collected indirectly from monitoring devices or by other means (for example, building and location access control and monitoring systems, Closed Circuit television, telephone logs and recordings and email and Internet access logs), if and to the extent permitted by applicable laws. In these circumstances, the data may be collected by Radius or a third party provider of the relevant service. This type of data is generally not accessed on a routine basis but access is possible. Access may occur, for instance, in situations where Radius is investigating possible violations of Radius policies such as those relating to travel and expense reimbursement, use of the telephone system and the Internet, or employee conduct generally, or where the data are needed for compliance or billing purposes. More frequent access to such data may occur incidental to an email surveillance program, if and to the extent permitted by applicable laws.

Where we ask you to provide personal information to us on a mandatory basis, we will inform you of this at the time of collection and in the event that particular information is required by the contract or statute this will be indicated. Failure to provide any mandatory information will mean that we cannot carry out certain HR processes. For example, if you do not provide us with your bank details, we will not be able to pay you. In some cases, it may mean that we are unable to continue with your employment or engagement as Radius will not have the personal information we believe to be necessary for the effective and efficient administration and management of our relationship with you.

Apart from personal information relating to yourself, you may also provide Radius with personal information of third parties, notably your dependents and other family members, for purposes of HR administration and management, including the administration of benefits and to contact your next-of-kin in an emergency. Before you provide such third party personal information to Radius you must first inform these third parties of any such data which you intend to provide to Radius and of the processing to be carried out by Radius, as detailed in this HR Privacy Notice.

What is the purpose and lawful basis for which data are processed?

Your personal information is collected and processed for various business purposes, in accordance with applicable laws and any applicable collective bargaining agreements. Data may occasionally be used for purposes not obvious to you where the circumstances warrant such use (e.g., in investigations or disciplinary proceedings). We may collect and process your personal information for various purposes, as set out in this HR Privacy Notice.

Where applicable data protection laws require us to process your personal information on the basis of a specific lawful justification, we generally process your personal information under one of the following bases:

the processing is necessary for the legitimate interests pursued by Radius (being those purposes described in the section above), except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information;
the processing is necessary for compliance with a legal obligation to which Radius is subject; or
the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract.

We may on occasion process your personal information for the purpose of the legitimate interests pursued by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information.

We have identified the following purposes for processing personal information. These purposes each relate to a lawful basis for processing, as required under applicable law. These purposes include:

No.	Purpose for processing	Lawful basis
a)	Recruitment and selection	This processing is necessary to take steps at the applicant's request to enter a contract of employment. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in fully assessing applications for employment to ensure that only suitable and appropriate candidates are both assessed and selected. Radius considers that this is important to ensure that Radius identifies the right people for its business who will be able to contribute to its operations and culture. Radius aims to recruit the best person for each vacancy through fair, systematic, effective recruitment and selection procedures. This will ensure that Radius continues to meet its business objectives, maintain its reputation and continues to attract high calibre employees.
b)	Appropriate vetting for recruitment and team allocation including, where relevant and appropriate credit checks, right to work verification, identity fraud checks, criminal record checks (if and to the extent permitted by applicable laws), relevant employment history, relevant regulatory status and professional qualifications;	This processing is necessary for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its business operations in the most effective way. Radius needs to make decisions relating to the future of its business in order to preserve its business operations or grow its business. These interests include the interests of the workforce as a whole and the Radius customer base. Radius considers business transformation to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
c)	Providing and administering remuneration, benefits and incentive schemes and reimbursement of business costs and expenses and making appropriate tax and social security deductions and contributions;	This processing is necessary to perform the contract between you and Radius. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes ensuring that employees are properly remunerated and that this remuneration is set an appropriate level and undertaking normal business operations. Radius considers effective employee management to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
d)	Allocating and managing duties and responsibilities and the business activities to which they relate, including business travel;	This processing is necessary to perform the contract between you and Radius. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes ensuring that each employee undertakes appropriate duties, are properly trained and undertake their roles correctly and in accordance with appropriate procedures and undertaking normal business operations. Radius considers effective employee management to support its long-term business goals and outcomes. Radius wishes to maintain its world class reputation and continue to attract high calibre employees.
e)	Identifying and communicating effectively with staff;	This processing is necessary to perform the contract between you and Radius. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes undertaking normal business operations and maintain a dialogue with employees. Radius considers effective employee management to support its long-term business goals and outcomes.
f)	Managing and operating appraisal, conduct, performance, capability, absence and grievance related reviews, allegations, complaints, investigations and processes and other informal and formal HR processes and making related management decisions;	This processing is necessary to perform the contract between you and Radius and for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes ensuring that each employee undertakes appropriate duties, are properly trained and undertake their roles correctly and in accordance with appropriate procedures. It also includes addressing employee related concerns and issues and resolving the same and complying with applicable laws and regulations. Radius considers effective employee management to support its long-term business goals and outcomes.
g)	Training, development, promotion, career and succession planning and business contingency planning;	This processing is necessary to perform the contract between you and Radius. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes ensuring that each employee undertakes appropriate duties, are properly trained and undertake their roles correctly and in accordance with appropriate procedures. Radius considers effective employee management to support its long-term business goals and outcomes.
h)	Consultations or negotiations with representatives of staff;	This processing is necessary for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes undertaking normal business operations and maintain a dialogue with employees and complying with applicable laws and regulations. Radius considers effective employee management to support its long-term business goals and outcomes. Radius wishes to maintain its world class reputation and continue to attract high calibre employees.
i)	Conducting surveys for benchmarking and identifying improved ways of working and employee relations and engagement at work (these will often be anonymous but may include profiling data such as age to support analysis of results);	This processing is necessary for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes ensuring that each employee undertakes appropriate duties, are properly trained and undertake their roles correctly and in accordance with appropriate procedures; undertaking normal business operations and maintain a dialogue with employees; ensuring that employees are properly remunerated and that this remuneration is set an appropriate level; and complying with applicable laws and regulations. Radius considers effective employee management to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
j)	Processing information about absence or medical information regarding physical or mental health or condition in order to: assess eligibility for incapacity or permanent disability related remuneration or benefits; determine fitness for work; facilitate a return to work; make adjustments or accommodations to duties or the workplace; make management decisions regarding employment or engagement or continued employment or engagement or redeployment; and conduct related management processes;	This processing is necessary for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes ensuring that each employee undertakes appropriate duties, are properly trained and undertake their roles correctly and in accordance with appropriate procedures and managing employee absence and leave entitlements.; This also includes undertaking normal business operations and maintain a dialogue with employees and complying with applicable laws and regulations. Radius considers effective employee management to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
k)	For planning, managing and carrying out restructuring or redundancies or other change programmes including appropriate consultation, selection, alternative employment searches and related management decisions;	This processing is necessary for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its business operations in the most effective way. Radius needs to make decisions relating to the future of its business in order to preserve its business operations or grow its business. These interests include the interests of the workforce as a whole and the Radius customer base. Radius considers business transformation to support its long-term business goals and outcomes. Radius wishes to maintain its world class reputation and continue to attract high calibre employees.
l)	Complying with reference requests where Radius is named by the individual as a referee;	Radius considers that it is in the legitimate interests of a new employer to receive confirmation of employment details from Radius for the purposes of confirming the former employee's employment history.
m)	Operating email, IT, internet, social media, HR related and other company policies and procedures. To the extent permitted by applicable laws, Radius carries out monitoring of Radius's IT systems to protect and maintain the integrity of Radius's IT systems and infrastructure; to ensure compliance with Radius's IT policies and to locate information through searches where needed for a legitimate business purpose;	This processing is necessary to perform the contract between you and Radius and for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. The HR IT function is essential to ensuring that this can be carried out in the most effective way. This includes maintaining the integrity and security of data and facilitating records management. Radius considers effective IT management to support its long-term business goals and outcomes. Radius wishes to maintain its world class reputation and continue to attract high calibre employees.
n)	Satisfying its regulatory obligations to supervise the persons employed or appointed by it to conduct business on its behalf, including preventing, detecting and investigating a wide range of activities and behaviours, whether relating to specific business dealings or to the workplace generally and liaising with regulatory authorities;	This processing is necessary for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in ensuring that its business, clients, employees and systems are protected. This includes detecting and preventing crimes or criminal activity; ensuring that only appropriate employees are engaged in our business; and ensuring compliance with requirements placed upon us (both by EU and non-EU laws). Radius considers effective business protection to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
o)	Protecting the private, confidential and proprietary information of Radius, its employees, its clients and third parties;	This processing is necessary for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in ensuring that its business, clients, employees and systems are protected. This includes protecting our assets and the integrity of our systems; and detecting and preventing loss of our confidential information and proprietary information. Radius considers effective business protection to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
p)	Complying with applicable laws and regulation (for example maternity or parental leave legislation, working time and health and safety legislation, taxation rules, worker consultation requirements, other employment laws and regulation to which Radius is subject in the conduct of its business);	This processing is necessary for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes ensuring that each employee undertakes appropriate duties, are properly trained and undertake their roles correctly and in accordance with appropriate procedures. It is also necessary to undertake normal business operations and maintain a dialogue with employees and comply with applicable laws and regulations. Radius considers effective employee management to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
q)	Planning, due diligence and implementation in relation to a commercial transaction or service transfer involving Radius that impacts on your relationship with Radius for example mergers and acquisitions or a transfer of your employment under applicable automatic transfer rules;	This processing is necessary for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its business operations in the most effective way. Radius needs to make decisions relating to the future of its business in order to preserve its business operations or grow its business. These interests include the interests of the workforce as a whole and the Radius customer base. Radius considers business transformation to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
r)	For business operational and reporting documentation such as the preparation of annual reports or tenders for work or client team records including the use of photographic images;	This processing is necessary to perform the contract between you and Radius. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes ensuring that each employee undertakes appropriate duties and undertaking normal business operations. Radius considers effective employee management to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
s)	To operate the relationship with third party suppliers including the disclosure of relevant vetting information in line with the appropriate requirements of customers to those customers, contact or professional CV details or photographic images for identification to clients or disclosure of information to data processors for the provision of services to Radius;	This processing is necessary to perform the contract between you and Radius. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes ensuring that each employee undertakes appropriate duties and undertaking normal business operations. Radius considers effective employee management to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
t)	Where relevant for publishing appropriate internal or external communications or publicity material including via social media in appropriate circumstances;	This processing is necessary to perform the contract between you and Radius. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes ensuring that each employee undertakes appropriate duties and undertaking normal business operations. Radius considers effective employee management to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
u)	To support HR administration and management and maintaining and processing general records necessary to manage the employment, worker or other relationship and operate the contract of employment or engagement;	This processing is necessary to perform the contract between you and Radius and for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. This includes ensuring that each employee undertakes appropriate duties, are properly trained and undertake their roles correctly and in accordance with appropriate procedures; managing employee absence and leave entitlements; undertaking normal business operations; maintaining a dialogue with employees; and complying with applicable laws and regulations. Radius considers effective employee management to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
v)	To change access permissions;	This processing is necessary to perform the contract between you and Radius and for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. The HR IT function is essential to ensuring that this can be carried out in the most effective way. This includes complying with Radius policies and access controls. Radius considers effective IT management to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
w)	To provide technical support and maintenance for HR information systems;	This processing is necessary to perform the contract between you and Radius and for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in managing its workforce and operating its business. The HR IT function is essential to ensuring that this can be carried out in the most effective way. This includes maintaining the integrity and security of data and facilitating records management. Radius considers effective IT management to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
x)	To enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you;	This processing is necessary to perform the contract between you and Radius and for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in protecting its organisation from breaches of legal obligations owed to it and to defend itself from litigation. This is needed to ensure that the company’s legal rights and interests are managed appropriately. Radius considers legal compliance and managing legal rights to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.
y)	To comply with lawful requests by public authorities (including without limitation to meet national security or law enforcement requirements), discovery requests, or where otherwise required or permitted by applicable laws, court orders, government regulations, or regulatory authorities (including without limitation data protection, tax and employment), whether within or outside your country;	This processing is necessary to perform the contract between you and Radius and for the compliance with legal obligations to which Radius is subject. This processing is also necessary for the purpose of the legitimate interests pursued by Radius. Radius considers that it has a legitimate interest in ensuring that it complies with all legal requirements placed on it, whether those are EU obligations or non-EU obligations. Radius wishes to maintain its reputation as a good corporate citizen and to act appropriately in all the countries in which it does business. This includes cooperating with authorities and government bodies. Indeed, Radius is required to comply with laws and regulations in those countries in which it does business and to require otherwise would lead to conflicts of laws issues. Radius considers legal compliance and managing legal rights to support its long-term business goals and outcomes. Radius wishes to maintain its reputation and continue to attract high calibre employees.

Additional information regarding specific processing of personal information may be notified to you locally or as set out in applicable policies.

Legal basis for processing

Processing special categories of personal information or sensitive data

The sensitive or special categories of personal information that may be processed by Radius are set out in this HR Privacy Notice.

Where applicable data protection laws require us to process such special categories of personal information on the basis of a specific lawful justification, we process the same under one of the following bases:

the processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or Radius in the field of employment law, social security and social protection law, to the extent permissible under applicable laws;
the processing is necessary for the purposes of preventive or occupational medicine, for the assessment of your working capacity, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, to the extent permitted by applicable laws;
the processing is necessary to protect your vital interests or of another person where you are physically or legally incapable of giving consent (for example in exceptional emergency situations, such as a medical emergency); or
the processing is necessary for the establishment, exercise or defence of legal claims.

This may include the following, although this is not an exhaustive list:

No.	Purpose for processing	Lawful basis
a)	Assess and review eligibility to work for Radius in the jurisdiction in which you work	This processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or Radius in the field of employment law, social security and social protection law, to the extent permissible under applicable laws.
b)	Compliance with employment, health and safety or social security laws. For example, to provide statutory incapacity or maternity benefits, avoid breaching legal duties to you, to ensure fair and lawful management of your employment, avoid unlawful termination of your employment, to administer Radius’s private medical and long term disability schemes, to make reasonable accommodations or adjustments and avoid unlawful discrimination or dealing with complaints arising in this regard;	This processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or Radius in the field of employment law, social security and social protection law, to the extent permissible under applicable laws. To the extent that this data is managed by our occupational health advisers, this processing is necessary for the purposes of preventive or occupational medicine, for the assessment of your working capacity, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, to the extent permitted by applicable laws.
c)	Management and investigation of any complaint under Radius's grievance policy (or other relevant policies), where such characteristics or information are relevant to the particular complaint, in order to comply with employment law obligations.	This processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or Radius in the field of employment law, social security and social protection law, to the extent permissible under applicable laws.

We may seek your consent to certain processing which is not otherwise justified under one of the above bases. If consent is required for the processing in question, it will be sought from you separately to ensure that it is freely given, informed and explicit. Information regarding such processing will be provided to you at the time that consent is requested, along with the impact of not providing any such consent. You should be aware that it is not a condition or requirement of your employment to agree to any request for consent from Radius.

Processing data relating to criminal convictions and offences

Personal information relating to criminal convictions and offences will only be processed where authorised by applicable laws.

For example:

a criminal record check may be carried out on recruitment or transfer where authorised by applicable laws; or
an allegation of a criminal offence or conviction arising during your relationship with Radius may be processed where required or authorised. For example, where we have a legal or regulatory requirement to report an offence or applicable laws authorise Radius to process information about the offence for the purpose of making decisions regarding your relationship with Radius.

Retention of personal information

Radius endeavours to ensure that personal information are kept as current as possible and that irrelevant or excessive data are deleted or made anonymous as soon as reasonably practicable. However, some personal information may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.

We will generally retain your personal information only so long as it is required for purposes for which it was collected. This will usually be the period of your employment/contract with us plus the length of any applicable statutory limitation period following your departure, although some data, such as pension information, may need to be kept for longer. We may keep some specific types of data, for example, tax records, for different periods of time, as required by applicable law.

Access to data

Within Radius, your personal information can be accessed by or may be disclosed internally on a need-to-know basis to:

Human Resources, including managers and team members;
management responsible for managing or making decisions in connection with your relationship with Radius or when involved in an HR process concerning your relationship with Radius;
system administrators; and
where necessary for the performance of specific tasks or system maintenance by staff in Radius teams such as the Finance, IT and the HR team.

Certain basic personal information, such as your name, location, job title, contact information and any published skills and experience profile may also be accessible to other employees. The security measures in place within Radius to protect your data are set out below.

Your personal information may also be accessed by third parties whom we work together with (including without limitation, SAGE Payroll Bureau, payroll providers, The People’s Pension, and Legal and General etc.) and their associated companies and sub-contractors) for providing us with services, such as hosting, supporting and maintaining the framework of our HR information systems.

Personal information may also be shared with certain interconnecting systems such as recruitment systems and local payroll and benefits systems. Data contained in such systems may be accessible by providers of those systems, their associated companies and sub-contractors.

Examples of third parties with whom your data will be shared include tax authorities, regulatory authorities, Radius's insurers, bankers, IT administrators, lawyers, auditors, investors, consultants and other professional advisors, payroll providers, and administrators of Radius's benefits programs. Radius expects such third parties to process any data disclosed to them in accordance with applicable law, including with respect to data confidentiality and security.

Where these third parties act as a "data processor" (for example, a payroll provider), they carry out their tasks on our behalf and upon our instructions for the above mentioned purposes. In this case your personal information will only be disclosed to these parties to the extent necessary to provide the required services.

In addition, we may share personal information with national authorities in order to comply with a legal obligation to which we are subject. This is for example the case in the framework of imminent or pending legal proceedings or a statutory audit.

Security of data

Radius uses a variety of technical and organisational methods to secure your personal information in accordance with applicable laws.

Radius is committed to protecting the security of the personal information you share with us. In support of this commitment, we have implemented appropriate technical, physical and organisational measures to ensure a level of security appropriate to the risk.

If you are in possession of personal information of any kind (e.g. data collected in emails, address books, Excel spreadsheets or contained in curricula vitae or elsewhere) you must ensure that the data are kept in a safe place where unauthorised access cannot occur. Where data is retained in hard copy, storage in a locked drawer or cabinet, accessible only to authorised individuals, is generally the most effective means of securing the data. Where data is kept in electronic form, appropriate password protection and appropriately secured areas should be used.

Transfer of personal information

From time to time your personal information (including special categories of personal information) will be transferred to associated companies of Radius to process for the purposes described in this HR Privacy Notice.

These associated companies may be located within the European Union or the United Kingdom (for example, Radius Limited, in the U.K.) and elsewhere in the world (for example, Radius Fleet Services Inc.). Personal information may also be transferred to third parties, as set out above.

As a result, your personal information may be transferred to countries outside of the country in which you work to countries whose data protection laws may be less stringent than yours.

Radius will ensure that appropriate or suitable safeguards are in place to protect your personal information and that transfer of your personal information is in compliance with applicable data protection laws. Where required by applicable data protection laws, Radius has ensured that service providers (including other Radius associated companies) sign standard contractual clauses as approved by the European Commission or other supervisory authority with jurisdiction over the relevant Radius exporter.

Your rights

Right to access, correct and delete your personal information

Radius aims to ensure that all personal information is correct. You also have a responsibility to ensure that changes in personal circumstances (for example, change of address and bank accounts) are notified to Radius so that we can ensure that your data is up-to-date.

You have the right to request access to any of your personal information that Radius may hold, and to request correction of any inaccurate data relating to you. You furthermore have the right to request deletion of any irrelevant data we hold about you.

You also have the following additional rights:

Data portability - where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that personal information is processed by automatic means, you have the right to receive all such personal information which you have provided to Radius in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
Right to restriction of processing - you have the right to restrict our processing of your personal information where:
- you contest the accuracy of the personal information until we have taken sufficient steps to correct or verify its accuracy;
- where the processing is unlawful but you do not want us to erase the data;
- where we no longer need the personal information for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or
- where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether Radius has compelling legitimate grounds to continue processing.

Where personal information is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.

Right to withdraw consent - where you have provided us with your consent to process data, you have the right to withdraw such consent at any time. You can do this by (i) in some cases deleting the relevant data from the relevant HR system (although note that in this case it may remain in back-ups and linked systems until it is deleted in accordance with our data retention policy) or (ii) contacting your local Human Resources contact.
Right to object to processing justified on legitimate interest grounds - where we are relying upon legitimate interest to process data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the processing of your personal information infringes applicable law.

CONTACT US

The primary point of contact for all issues arising from this privacy notice, is our Data Protection Officer. The Data Protection Officer can be contacted via:

dataprotectionofficer@radiuspaymentsolutions.com; or
The Data Protection Officer, Radius Limited, Eurocard Centre, Herald Park, Herald Drive, Crewe CW1 6EG

If you have any questions or concerns regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

Additional Privacy Notices

We may undertake certain processing of personal information which are subject to additional Privacy Notices and we shall bring these to your attention where they engage.

Notice of changes

Radius may change or update this HR Privacy Notice at any time.

Should we change our approach to data protection, you will be informed of these changes or made aware that we have updated the HR Privacy Notice so that you know which information we process and how we use this information.

This HR Privacy Notice was last updated and reviewed on 4^th August 2021 – Version 1.2