Privacy Policy

Employee privacy notice

This privacy notice explains how we process your personal information in accordance with applicable data protection laws, including the Data Protection Act 2018 and Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR). It details the following:

  • Who we are

  • Why we collect and process your personal information

  • What our legal basis for processing your personal information is

  • What personal information we collect about you and how we obtain it

  • Who we share your personal information with and why

  • Our approach to international transfers

  • How long we keep your personal information

  • What your data protection rights are

  • How to contact the Information Commissioners Office 

Who we are

RWE (The company, we, us and our) is registered with the Information Commissioner’s Office as follows:

 

RWE Generation UK plc - Z4617964, RWE Supply and Trading GmbH - ZA394620, RWE Technology UK Limited   - ZA383014, RWE Renewables Management UK Ltd - 12087808, and are the data controller of your personal information.

 

If you have any queries in relation to how we process your personal information, or regarding anything in this notice, you should contact our Data Protection Officer, Julie Benfell on Julie.Benfell@rwe.com  

 

Why we collect and process your personal information

We collect, store, and process personal information about prospective, current and former staff to ensure compliance with legal or industry requirements in the field of employment and to effectively perform our role as a responsible employer.

 

We process your personal information to consider your application when you apply for a position with us. If you become an employee, we process your personal information for a number of purposes, including: 

 

•  Staff administration and management (including payroll and performance)

•  Pensions administration

•  Education, training and talent management

•  Occupational health

•  Business management and planning

•  Accounting and Auditing

•  Accounts and records

•  Health surveillance, including drug and alcohol testing

•  Crime and fraud prevention

•  Health, safety and security

 

Your personal information may be converted into statistical or aggregated data which is then used to produce statistical research and reports for the purposes described above.

 

What our legal basis for processing your personal information is

The Company processes personal information under a number of lawful bases, including:  

 

  • As necessary to enter into a contract of employment with you. When you apply for a position, this will be to take steps at your request prior to entering into a contract with you. If you are accepted for a position, to provide you with that contract and meet the obligations under that contract (e.g. to pay you and administer your benefits).

  • As necessary for the Company’s own legitimate interests or those of other persons or organisations, such as to:  

-              run recruitment and promotion processes;

-              maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of your contractual and statutory rights;

-              operate and keep a record of disciplinary and grievance processes;

-              ensure acceptable conduct within the workplace;

-              operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes;

-              operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that all employees are receiving the pay or other benefits to which they are entitled;

-              ensure that it complies with its duties in relation to individuals with disabilities;

-              ensure that all employees are receiving the pay or other benefits to which they are entitled;

-              operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that the organisation complies with duties in relation to leave entitlement;

-              ensure effective general HR and business administration;

-              provide references on request for current or former employees;

-              respond to and defend against legal claims;

-              maintain and promote equality in the workplace and;

-              business management and planning such as analysis of travel patterns 

  • As necessary to comply with our legal obligations, for example, under health and safety and employment laws.  

When we process information about health or medical conditions, which is a special category of personal information, this is processed to carry out obligations under employment law, such as those in relation to employees with disabilities obligations and to assess the working capacity of our employees; for the purposes of engaging occupational health professional in connection with any relevant preventive or occupational medicine, medical diagnosis, staff alcohol and drug testing; the provision of health or social care or treatment of the management of health or social care systems and services. We may process this and other special categories of personal information, such as race or ethnicity, or criminal convictions data on the basis of other law obligations such as health and safety or with your explicit consent. Alternatively we may process this information on an anonymous basis.

 

When we process your personal information on the basis of your consent, this can be withdrawn at any time. This will not affect the lawfulness of any processing that was carried out based on your consent before you withdrew it.

 

Employees are entirely free to decide whether or not to provide information regarding race and ethnicity, there are no consequences of failing to do so. We require other types of personal data to consider your application for employment and to fulfil our obligations as an employer. For example, during the application process, we require information regarding your qualifications and experience to be able to assess your application.

 

When you are employed with us, we require your banking details to be able to pay you.

 

What personal information we collect about you and how we obtain it

Personal information about you will largely be collected directly from you during the recruitment and employment process for example through online application forms, CVs or resumes, passport or other identity documents such as your  driving licence and forms completed at the start of and during your employment.

 

Personal information may also be collected from third parties in certain circumstances such as your previous employer, recruitment agency or through national checks such as the Disclosure and Barring Service.

 

The types of personal information we collect include:

 

Personal information  

 

  • Personal demographics including marital status, gender, race, nationality, ethnicity, sexual orientation, religion  (for diversity and inclusion monitoring)

  • Contact details such as name, addresses, telephone numbers and emergency contact details

  • Your image, such as photograph or CCTV image

  • Voice recordings

  • Employment records (including professional membership, qualifications, references and proof of eligibility to work in the UK and security checks)

  • Bank details

  • Pension details

  • Insurance cover   

 

Special categories of personal information 

 

  • Occupational health information (medical information including physical health or mental condition ) including whether you have a disability and reasonable adjustments made

  • Information relating to health and safety

  • Trade union membership   

We may also process information related to offences (including alleged offences), criminal proceedings, outcomes and sentences to satisfy our legal obligations such as the financial regulation framework.

 

Throughout any period of employment with us we will record personal information about you. For example, working pattern details, work attendance including periods of leave, assessments of your performance and related correspondence. We may also process personal information relating to any employment tribunal applications, complaints, accidents, and/or incidents.

 

Who we share your personal information with and why

We may share your personal information with third parties to ensure that we fulfil our contractual obligations with you and so that you receive your entitlement to compensation and benefit arrangements which have either been requested by you and/or which the Company is obligated to provide.

 

These third parties include any company within our Group that provides us with payroll support, third parties that provide us with services, such as health benefits or pension schemes, and government bodies such as HMRC.

 

We may be required to share information where we are required to do so to comply with any legal obligation, for example, to enforcement bodies or fraud prevention agencies in order to help prevent and detect fraud or to professional bodies during disciplinary or investigatory processes.

 

Any disclosures of personal data are always made on a case-by-case basis, disclosing the minimum personal information necessary for the specific purpose and circumstances and with the appropriate security controls in place.

 

Where possible, we will always look to anonymise or pseudonymise your personal information so as to protect confidentiality. 

 

Our approach to international transfers 

We do not systematically transfer your personal information outside the European Economic Area. If we do make any such transfers, we will ensure that there are appropriate safeguards in place to comply with applicable data protection laws.

 

How long we keep your personal information 

Your personal information may be held in both paper and electronic forms in accordance with our retention periods.

 

We hold your personal information throughout your employment in accordance with regulatory or industry retention periods.

 

If you make an application for employment but are not offered a role with us, we may hold your personal information for a period of six months following the end of the particular recruitment campaign that you submitted your application under.

 

What your data protection rights are 

You have various rights under data protection laws, including the right to: 

 

  • access the personal information we hold about you (known as a subject access request)

  • request correction of inaccurate or incomplete information that we hold about you

  • request that your information be deleted in certain circumstances (sometimes known as the right to be forgotten);

  • request that we restrict the use of your information in certain circumstances;

  • request that we copy or transfer your information from one IT system to another in a safe and secure way, without impacting the quality of the information in certain circumstances;

  • object to how your personal information is used in certain circumstances;

  • challenge any decisions made without human intervention (automated decision making). 

If you wish to exercise any of your data protection rights, or have a query relating to them, please contact the Data Protection Officer on julie.benfell@rwe.com .

 

The Information Commissioner’s Office 

The Information Commissioner’s Office (ICO) is the regulatory body for data protection matters in the UK.

 

You have the right to make a complaint to the ICO, but they typically will not investigate unless you have made a complaint to the Company in the first instance. 

 

You can contact the ICO as detailed below: 

 

  • Writing to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

  • Telephoning: 0303 123 1113 (local rate)

  • Faxing: 01625 524 510

  • Website submission: https://ico.org.uk/make-a-complaint/