Privacy Policy

Where we carry out screening on behalf of a client (your prospective or current employer), that client is the “data controller” of the personal information processed for the screening, and Secure Screening Services Limited acts as their “data processor”, processing it on their instructions. Secure Screening Services Limited is also a “data controller” in its own right for the purposes we determine ourselves — for example, complying with our own legal and regulatory obligations, retaining records of completed screenings, offering re-screening and handling complaints. This notice explains how we handle your personal information in both capacities. We are required under data protection legislation to notify you of the information contained in this privacy notice. This notice applies to prospective, current and former candidates for screening, to our clients’ representatives, and to users of our website and services.

This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.

We will collect, store, and use the following categories of personal information about you:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• Date of birth.
• Gender.
• Location of employment or workplace.
• Copy of driving licence.
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
• Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).
• Performance information.
• Disciplinary and grievance information.
• Information about your use of our information and communications systems.
• Photographs.
• Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied. We may also collect, store and use the following more sensitive types of personal information:
• Details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and
• Where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.
• Biometric data.
• Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or other background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies including the Disclosure and Barring Service.

We will collect additional personal information in the course of job-related activities throughout the period of you working for the business for which you are employed as a worker or a contractor.

How will we use this information about you?

Where we screen you on behalf of a client, our client, as the data controller, determines the lawful basis for the screening. We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the contract for which we have entered into with your employer to screen your application with them.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with our client (your prospective employer) (*) and to enable us to comply with legal obligations (**). In some cases, we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information, as well as providing a description of which categories of data are involved. Where a legitimate interest is involved, we state what the legitimate interest is.

• Carrying out the screening checks our client has instructed us to perform.*
• Verifying the information and documents you provide as part of your screening.*
• Checking you are legally entitled to work in the UK.**
• Reporting verified results to our client so that they can make their recruitment or appointment decision.* Some of the above grounds for processing will overlap and there may be several grounds which justify the use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with your potential employer which may prevent your application with them from proceeding.

Change of purpose

We use your personal information only for the purposes instructed by our client, or for the limited purposes of our own described in this notice. We do not reuse screening data for other purposes. If the purposes for which your personal information is processed ever need to change, our client (as controller) will determine the lawful basis for the new purpose, and you will be notified.

How we use particularly sensitive information

“Special categories” of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.
2. On our client’s instructions, where our client has identified an applicable Article 9 condition for the screening.
3. Where it is needed in the public interest, such as for equal opportunities monitoring.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Situations in which we will use your sensitive personal information

In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with your prospective employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below. We have indicated the purpose or purposes for which we are processing or will process your more sensitive personal information.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with your employer that you agree to any request for consent from us.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. Our client, as the data controller, determines the Article 6 lawful basis and the applicable condition under Schedule 1 of the Data Protection Act 2018 for criminal-records checks, and we carry them out on their instructions and in line with our privacy standard.

We envisage that we will hold information about criminal convictions.

We will only collect information about criminal convictions if it is appropriate given the nature of the role for which you are applying and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process. We will use information about criminal convictions and offences to allow your prospective employer to consider your suitability for employment or becoming a worker or contractor.

We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision- making in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request our consideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision- making, unless we have a lawful basis for doing so and we have notified you.

Data sharing

We may have to share your data with third parties, including prospective employers and third-party service providers.

We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the UK.

If we do, we will ensure the transfer is protected by appropriate safeguards as required by the UK GDPR — for example, a UK adequacy regulation covering the destination country, or an International Data Transfer Agreement (or the UK Addendum to the EU Standard Contractual Clauses) — so that your personal information receives an equivalent standard of protection.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to process your application to become an employee, worker or contractor or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: Disclosure and Barring service – To check criminal history. Equifax to check credit history. GBG Group to Check driving licence history, criminal history, credit history and right to work. HEDD and Qualification check for qualification verification. Any other background checking services introduced as a data supplier. A full list of our current sub-processors is published in our Data Privacy Agreement.

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC and disclosures to shareholders such as directors’ remuneration reporting requirements.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Secure Screening Services, Data Protection Officer.

We have put in place procedures 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.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are set out in our Data Retention Policy, or are available from the Data Protection Officer at [email protected]. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the employer for whom we are providing screening services we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

Rights of access, correction, erasure and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your application for employment or become a worker or contractor.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing(see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer at [email protected] or in writing to our registered office.

Where your request relates to processing we carry out on behalf of a client, we will refer it to the client without undue delay and will not respond substantively without their instruction, except where the request concerns processing for which we are the controller.

We will respond to a data subject access request within one month of receipt. Where a request is complex, or where we receive a number of requests from you, we may extend this period by up to a further two months; if so, we will tell you within one month of receiving your request and explain why. In line with the UK GDPR (as amended by the Data (Use and Access) Act 2025), we will carry out a reasonable and proportionate search for the information requested, and the response period may be paused where we need further information from you to confirm your identity or to clarify the scope of your request.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your
consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer at [email protected].

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection officer

We have appointed a Data Protection Officer (DPO), Martin Price, to oversee compliance with this privacy notice. If you have any questions about how we handle your personal information, please contact the DPO at [email protected].

Data protection complaints

If you are unhappy with how we have used your personal information, you have the right to make a complaint to us. Please send your complaint to our Data Protection Officer at [email protected], or in writing to Secure Screening Services Limited, Unit 5 Vitrage Technical Park, 27 Witney Road, Nuffield Industrial Estate, Poole, Dorset, BH17 0GL.

In accordance with the Data (Use and Access) Act 2025, we will acknowledge your complaint within 30 days of receiving it, investigate it, and inform you of the outcome without undue delay.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, although we would welcome the opportunity to address your concerns first.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact our Data Protection Officer, Martin Price, at [email protected], or alternatively in writing at: Secure Screening Services. Unit 5 Vitrage Technical Park, 27 Witney Road, Nuffield Industrial Estate, Poole, Dorset, BH17 0GL