Privacy notice : Human Resources

Who are we

RBWM Council 
Human Resources (HR)
Town Hall, 
St Ives Road,

The lawful basis for processing the information

In accordance with the GDPR 2018 Article 6 our legal basis for processing personal information is:

  • Article 6 1(b) Processing is necessary for performance of a contract.
  • Article 6 1(c) Processing is necessary for compliance with a legal obligation.
  • Article 6 1(f) Processing is necessary for the purposes of legitimate interests.
  • Article 6(1) (e) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Our legal basis for processing Article 9 GDPR 2018 special category information is:

  • Article 9 2(b) Processing is necessary in the field of employment and social security and social protection law
  • Article 9 2(g) Processing is necessary for reasons of substantial public interest.
  • Schedule 1 part 1 or 2 of the DPA 2018 to process special category data as it is necessary for:
    -    Obligations in connection with employment
    -    Purposes of equal opportunities.

Our legal basis for processing criminal conviction information is:

  • Part 1(1)(1)(a) of the Data Protection Act – obligations in connection with employment to ensure that individuals are permitted to undertake their job role in line with:

How do we collect information from you

  • HR forms (online and paper copies)
  • By email, letter, interview/meeting notes 
  • Job application forms submitted online, by email, post.
  • Agency pro-formas 
  • DBS application
  • Occupational health referrals
  • Third parties electronically and/or hard copy such as pension providers, AVC provider, HMRC, HM Courts and Tribunal Service, Contributions Agency, the council’s employee benefits providers including Sodexo and NHS Fleet Solutions, trade unions - GMB and Unison.
  • iTrent HR system for recording pay details, absences, overtime, expenses/mileage, claims.
  • Online incident report forms
  • Emailed forms sent form schools and internal council services
  • By the Learning and development software system including, iHasco and Skillsoft.

What type of information is collected from you

Human Resources

  • Personal details including name, addresses, email address, date of birth, contact number
  • Emergency contact(s)
  • Information processed under the Equality Act 2010; including, age, sex, race, disability, gender reassignment, marriage/civil partnership, religion/belief and sexual orientation.
  • Criminal convictions and cautions
  • Disciplinary, grievance, capability, health information. 
  • Health and absence information.


  • Date of marriage
  • National Insurance number
  • Personal bank account number
  • Tax code
  • AVC payment value
  • Salary sacrifice benefit value, value of official deductions including union subscriptions, court order payments, jury service payments etc.
  • Monthly variable data including overtime hours, standby claims, mileage and other expenses.
  • Absence information.

Health and Safety

  • Name
  • Personal address
  • Contact number
  • Date of birth
  • Details of incident including injuries and first aid treatment given.

Learning and Development

  • Name
  • Email address

How we use the information you have provided

We process your personal information to:

Human Resources

  • Process HR enquiries and deliver our services to you.
  • Assess applicants for shortlisting and appointment, to determine your suitability for employment.
  • Communicate and contact employees.
  • Enable processing of salary and other payments.
  • Enrol you to a pension scheme.
  • Manage employees through the employee lifecycle such as; joining, probation, job transfers, assessing capability, managing disciplinary, absences, restructuring, salary changes, retirement, termination, transfer to other organisations etc.
  • Equality information in line with statutory requirements 
  • Assess an application for specific benefits e.g. childcare vouchers.
  • Confirm your identity.
  • Monitor our workforce and produce internal anonymised statistical analysis
  • Manage your performance.
  • Enable us to comply with the Local Government Transparency Code 2015 which requires publication of information on the Council’s website.


  • Process payments for various absences.
  • Assess pension scheme contribution and administer your entitlement.
  • Manage and process statutory and voluntary deductions from employee pay.

Health and Safety

  • Log accident reports and carry out accident investigations.

Who has access to the information about you

RBWM Council employees including Human Resources, Learning and Development, Payroll and Health and Safety Officers. 

Who we may share your information with

How long we store your information

Human Resources

  • Unsuccessful job applicants – 6 months.
  • Employment records – 7* years after termination of employment (6 tax years plus current tax year) in electronic document management system, plus word, and PDF documents on secure network.
  • Employee pay and benefits records – 7* years after termination of employment in word, excel and PDF documents on secure network.


  • All payroll related records – 7* years after termination of employment. Electronically within Payroll system, excel/word documents on secure network.
  • Associated pension records - 10 years after change. Electronically within Payroll system, excel/word documents on secure network.
  • Overtime and other monthly claims from schools - 7 years after termination of employment.

Health and Safety

Accident records including RIDDOR– 3* years or where a child, until age 21. COSHH – 40 years.  
Learning and Development

Record of learning 7# years after course completed or person leaves organisation on the management of learning records software system.

iTrent Systems team

Emails to help desk - personal information. Until the Call is resolved + plus 12 month for monitoring of issues. Outlook email / shared inbox & Excel Spreadsheet on secure network.

Phone calls to help desk – personal. Until the Call is resolved + plus 12 months for monitoring of issues.

Excel Spreadsheet on secure network.

* For those working with children, 25 years.
# For those working with children 40 years.

Does your service utilise automate decision making? – No.  

Further information

If you would like to know more about how we use your information or like to inform us of a change to your contact details, please contact us using the details above.