Data Protection & Privacy Policy

1. WHAT IS THE PURPOSE OF THIS DOCUMENT?

Key points:
WF Pay Ltd. is committed to protecting the privacy and security of your personal information.
This Data Protection Policy and Privacy Notice describes how we collect and use personal information about you during and after your working relationship with us. This is in accordance with the UK Data Protection Act (2018) and the EU General Data Protection Regulation (GDPR), laws which govern the way that personal data of UK and EU citizens is handled by any organisation.

These laws, and therefore this policy and privacy notice, apply to all current and former employees, workers and freelance contractors, and in part, to interns and volunteers.
We want to be very clear about our responsibilities in relation to the way we protect data, so that you can be sure of what our expectations are. This is the primary purpose of this document; so that you understand our position, and what we expect of you.

In respect of our relationship with data, WF Pay Ltd. is a “controller” (also called a “data controller”). This means that we are responsible for deciding why, and how we hold and use personal information about you. It is important that we are transparent about how we handle personal data, and it is a requirement under data protection legislation to let you know. That is why we have written this privacy notice and policy.
This is a long document and contains a lot of information. However, it is important that you are aware of how we treat your data and what we expect of anyone who comes into contact with data in their day‑to‑day activities within WF Pay Ltd.

Please take time to review this document and if you have any queries, please contact dplead@wfpayltd.co.uk.
We may update this notice at any time and, where there are considerable changes, we will inform you. However, it is important that you regularly review this Notice and Policy to remain up to date with our expectations and role.

2. DATA PROTECTION PRINCIPLES

In line with data protection law, we must ensure personal information is:

• Used lawfully, fairly and in a transparent way.

• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

• Relevant to the purposes we have told you about and limited only to those purposes.

• Accurate and kept up to date.

• Held only as long as necessary for the purposes we have told you about.

• Held securely.
   

3. THE KIND OF INFORMATION WE HOLD ABOUT YOU

Key points:
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 “special categories” 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.
In more detail:
We may 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.

• Marital status and dependants.

• Next of kin and emergency contact information.

• National Insurance number.

• Bank account details, payroll records and tax status information.

• Salary, annual leave, pension and benefits information.

• Start date and, if different, the date of your continuous employment/engagement.

• Leaving date and your reason for leaving.

• Location of employment or workplace.

• Copy of driving licence.

• Recruitment information (including copies of right to work documentation, references and information included in a CV or cover letter).

• Employment records (including job titles, work history, working hours, training records and professional memberships).

• Compensation history.

• Performance information.

• Disciplinary and grievance information.

• CCTV footage and other electronic records such as swipe card data.

• Information about your use of our information and communications systems.

• Photographs.

• Passport, visa, right‑to‑work documents and/or sponsorship papers.

• Results of HMRC employment status checks.
   

We may also collect, store and use the following special categories of personal information:

• Information about race or ethnicity, religious beliefs, sexual orientation and political opinions.

• Trade union membership.

• Health, medical, sickness and absence records.

• Genetic and biometric data.

• Information about criminal convictions and offences.
   

4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We collect personal information through the recruitment process, directly from individuals, employment agencies, umbrella companies, online sources (including LinkedIn), CV databases and background check providers.
We may also collect information from referees, former employers, pension trustees, professional advisers, and relevant service providers.
We will collect additional personal information throughout the period of your engagement with WF Pay Ltd.
Data is stored securely on encrypted servers with appropriate access controls.

5. HOW WE WILL USE INFORMATION ABOUT YOU

Key points:
We will only use your personal information where the law allows us, including:

• To perform a contract.

• To comply with a legal obligation.

• For legitimate business interests.

• With consent, where required.

Situations in which we will use your personal information include:

• Recruitment and engagement decisions.

• Payroll and statutory deductions.

• Pension auto‑enrolment and benefits administration.

• Managing working relationships.

• Compliance with HMRC, employment and health & safety law.

• Performance management.

• Training and development.

• Disciplinary and grievance procedures.

• Preventing fraud and ensuring system security.

• Legal disputes and insurance matters.

If you fail to provide required personal information, we may be unable to meet contractual or legal obligations.
We will not use personal data for unrelated purposes without informing you.

6. HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION

We will only process special category personal data where:

• Required by law.

• Necessary for employment obligations.

• Needed to assess fitness for work or provide workplace adjustments.

• Required for statutory payments and benefits.

Consent will only be requested where legally necessary.

7. INFORMATION ABOUT CRIMINAL CONVICTIONS

We only process criminal convictions data where permitted by law and relevant to the role or assignment.
This may occur during recruitment or if disclosed during engagement.

8. AUTOMATED DECISION‑MAKING

WF Pay Ltd does not currently make decisions based solely on automated processing. If this changes, you will be informed in advance.

9. DATA SHARING

We may share your personal information with:

• HM Revenue & Customs

• Pension providers

• Payroll and IT service providers

• Professional advisers (lawyers, auditors, insurers)

• Regulators and authorities

All third parties are required to protect your information and process it only in accordance with our instructions.

10. DATA SECURITY

We have implemented appropriate measures to protect personal data from unauthorised access, loss or misuse.
Access is restricted to authorised individuals, all of whom are subject to confidentiality obligations.

11. DATA RETENTION

Personal data is retained only for as long as necessary to fulfil contractual, legal and regulatory obligations. Data is securely destroyed when no longer required.

12. RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION

You have the right to:

• Access your personal data

• Request correction

• Request erasure

• Restrict processing

• Object to processing

• Request data portability

Requests should be made in writing to the Data Protection Officer.

13. RIGHT TO WITHDRAW CONSENT

Where processing is based on consent, you may withdraw that consent at any time by contacting dplead@wfpayltd.co.uk.

14. DATA PROTECTION CONTACT

If you have any questions or concerns regarding this notice, please contact:
📧 dplead@wfpayltd.co.uk
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

15. CHANGES TO THIS PRIVACY NOTICE

This privacy notice is not contractual. We reserve the right to update it at any time and will provide a revised version when significant changes are made.