United Kingdom
United States
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This notice should be read in conjunction with the Overview
Ethics reporting
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What processing activities do you undertake that include my personal information?We operate an Ethics Reporting line, which allows employees (and their next of kin), contractors, customers, contacts, suppliers and members of the general public to raise any concerns to us which will then be managed in accordance with our applicable policies.
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What categories of personal information are included in these processing activities?To run the process set out above, depending on your relationship with us and the type of concern raised, we process Identity Information, Staff related data, Data related to your engagement with the Company, Recruitment data, Regulatory data, Vetting data, Remuneration and benefits data, Leave information, HR processes data, Monitoring data (to the extent permitted by applicable laws) and Employment claims, complaints and disclosures data.We may also incidentally process special categories of personal information and criminal records information, to the extent permitted by applicable laws.
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What is the purpose of these activities?We carry out these activities to protect our business. In particular, we do so in order to ensure compliance with applicable laws and Company policies and procedures, to monitor use of the Company’s IT system and to manage the activities and behaviour of our employees.
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What are the legal grounds you rely on to carry these out?This processing is necessary for the compliance with legal obligations to which the Company is subject.This processing is also necessary for the purpose of the legitimate interests pursued by the Company.(See “What are the legal grounds for processing personal information?” in the Overview section).
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What are the 'legitimate interests' referred to above?The Company considers that it has a legitimate interest in ensuring that its business, clients, staff members and systems are protected.This includes responding appropriately to ethics concerns which are raised to it.
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As this processing may include special categories of personal information or information relating to my criminal record, in addition to the above, what are the additional legal grounds you rely on to justify this processing?This processing is necessary for substantial public interests.(See “What are the legal grounds for processing special category personal information?” in the Overview section.)
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To the extent that you did not get this personal information from me, how did you collect this information?Some of the information processed in these activities may be generated by the Company. This would usually include line management, Security and Compliance (see “Where do you get my personal information from?” in the Overview section).In addition, we may work with business partners and suppliers to carry out this activity and as set out in this Notice. We may receive information from other sources as set out in this Notice (see “Where do you get my personal information from?” in the Overview section).
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Who do you share this personal information with?Your personal information is shared internally, as set out in this Notice (see “When do you share my personal information with others?” in the Overview section).This would usually include HR and your line management.In addition, some of your personal information will be shared externally with any suppliers or partners as needed, external agencies (including the Police or law enforcement, as appropriate) and as otherwise set out in this Notice (see “When you do you share my information with others?” in the Overview section).