Privacy Notice Employment Candidates and Employees
When Cinnamon Luxury Care processes your personal data, it is required to comply with the Data Protection Act 2018 , the UK GDPR and other laws and regulations governing the processing of personal data (together referred to as the “Data Protection Legislation”).
Your personal data is all the information we hold relating to you as an identified or identifiable natural person (for example, your name, email address, postal address, date of birth, location data and in some cases opinions that we document about you; as well as special categories of data, including medical and health records, and information about your religious beliefs, ethnic origin and race, sexual orientation, trade union membership and political views).
Processing your personal data covers most things we do with it, including collecting, storing, amending, transferring and deleting it.
This privacy notice provides information about the personal data we process, why we process it and how we process it.
Who we are
Cinnamon Luxury Care is the brand name used by a number of Care Homes and Retirement Villages run by different companies within the same corporate group. When this privacy notice refers to Cinnamon Luxury Care it means the company that runs a particular Care Home or Retirement Village.
Cinnamon Care Collection Limited (company number 10057697) provides data protection support to all companies within the Cinnamon Luxury Care Group, and provides the Data Protection Officer (DPO) for each of them.
The DPO has day to day responsibility for ensuring that we comply with the Data Protection Legislation and for dealing with any requests we receive from individuals exercising their rights under the Data Protection Legislation.
You can contact the DPO, or obtain details of the company that runs a particular Care Home or Retirement Village and is the data controller for it, by writing to Cinnamon Care Collection Ltd as below:
Cinnamon Care Collection Limited, 24 Adam & Eve Mews, Kensington, London W8 6UJ
Or by email to dpo@cinnamoncc.com
What personal data do we process about you?
We process your personal data for recruitment, HR, employment and administrative purposes. We need your personal data to make sure you have all you need to be able to work for Cinnamon Luxury Care, to make sure you are safe and secure at work and to make sure you receive all the benefits and rights to which you are entitled.
Personal data that we may process about you, and the relevant legal basis for processing that personal data, includes:
| Type of Data | Legal basis for processing |
| Identity data such as your first name, middle names, last name, date of birth and gender | Legal obligation |
| Marital status and title | Legitimate interests (collecting demographic information about employees and candidates to effectively manage our operations) |
| Contact data such as your postal address, email address and telephone numbers | Legitimate interests (having in place effective contact arrangements with employees and candidates) |
| Immigration checks | Legal obligation |
| Financial data including your bank account details, payroll records and tax status information | Legal obligation |
| National Insurance number | Legal obligation |
| Next of kin and emergency contact information | Legitimate interests (having in place effective contact arrangements to manage emergency situations involving employees and candidates) |
| Information about your dependents | Contractual requirement |
| Background data such as your education, career background and work experience | Legitimate interests (collecting demographic information about employees and candidates to effectively manage our operations) |
| Personal information such as your skills and qualities | Legitimate interests (collecting skills information about employees and candidates to effectively manage our operations) |
| Salary, annual leave and pension information | Legal obligation |
| Benefits information including life assurance and ill health cover | Contractual requirement |
| Start date and, if different, the date of your continuous employment | Legal obligation |
| Leaving date | Legal obligation |
| Your reason for leaving | Legitimate interests (understanding issues in our work force to effectively manage our operations) |
| Location of employment or workplace | Legal obligation |
| Copy of passport | Legal obligation |
| Employment records including job titles and work history | Legitimate interests (collecting demographic information about employees and candidates to effectively manage our operations) |
| Training records | Legal obligation or legitimate interests, depending on the type of Training (where legitimate interests, effectively managing our operations) |
| Information about working hours and holidays | Legal obligation |
| Maternity and paternity leave information | Legal obligation |
| Performance information | Legitimate interests (collecting performance information about employees to effectively manage our operations) |
| Disciplinary and grievance information | Legal obligation |
| Accident records | Legal obligation |
| CCTV images | Legitimate interests (the prevention and detection of crime, employee and resident safety) |
| Information about your ethnicity/racial background | Legitimate interests (collecting demographic information about employees and candidates to effectively manage our operations) Condition for processing special category data: Consent – provision of this information is voluntary |
| Special categories of data to the extent we need such information to make sure you are comfortable and safe at work including information relating to your health and medical conditions | Legal obligation Condition for processing special category data: necessary for the purposes of carrying out the obligations and exercising specific rights as your employer |
| Any other information included on any CV, application or covering letter you provided to us | Legitimate interests (collecting skills information about employees and candidates to effectively manage our operations) |
If we obtain consent from you to the processing of your personal data, you can withdraw your consent at any time. This will not affect the lawfulness of any processing we carried out prior to you withdrawing your consent.
Who will receive your personal data?
We only transfer your personal data to the extent we need to. Recipients of your personal data include:
- Payroll and external healthcare providers
- IT service providers
- Third parties that provide benefits / perks
- Safeguarding authorities, commissioning bodies and ICBs
- The Police and other law enforcement agencies
- Training course providers
- Auditors / professional advisors (including solicitors and insurers)
Wherever possible we ensure that any data necessary to be shared with other organisations remains within the UK or the EEA. However, some organisations that we may share your personal data with are located in, or run their services from, countries outside of these areas and as a result your personal data may be transferred to countries outside of these areas.
How long will we keep your personal data?
We will only keep your information for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, contractual or reporting requirements. Your information will be kept securely at all times.
Following the end of the relevant retention period, your files and the personal data covered by the retention period will be permanently deleted or destroyed.
What are your rights?
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised the rights which may be available to you below, depending on the grounds on which we process your data. More information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide- to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data.
1. Access to your data
You have the right to ask us to confirm that we process your personal data, as well as having the right to request access to/copies of your personal data. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this privacy notice.
We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.
We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we will let you know.
2. Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it unless we do not feel it is appropriate, in which case we will let you know why. We will also let you know if we need more time to comply with your request.
3. Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:
- Where we no longer need your personal data for the purpose for which we collected it
- Where we have collected your personal data on the grounds of consent and you withdraw that consent
- Where you object to the processing and we do not have any overriding legitimate interests to continue processing the data
- Where we have unlawfully processed your personal data (i.e. we have failed to comply with UK GDPR); and
- Where the personal data has to be deleted to comply with a legal obligation
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we will let you know.
4. Right to restrict processing
In some circumstances, you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we do not have to delete it. This right is available to you:
- If you believe the personal data we hold is not accurate – we will cease processing it until we can verify its accuracy
- If you have objected to us processing the data – we will cease processing it until we have determined whether our legitimate interests override your objection
- If the processing is unlawful; or
- If we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim
5. Data portability
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:
- Where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
- Where we carry out the processing by automated means
We will respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we will let you know.
6. Right to object
You are entitled to object to us processing your personal data:
- If the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority
- For direct marketing purposes (including profiling); and/or
- For the purposes of scientific or historical research and statistics
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling, legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
Automated decision making
Automated decision making means making a decision solely by automated means without any human involvement.
We do not carry out any automated decision making using your personal data.
Your right to complain about our processing
If you have a complaint about how we have processed your personal data, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website: https://ico.org.uk/concerns/.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time. Where we make any change to this privacy notice which materially affects your rights and freedoms in respect of personal data we will notify you.
Any questions?
If you have any questions or would like more information about the ways in which we process your data, please contact dpo@cinnamoncc.com