Our Privacy Notice

Job Applicant, Employee, Worker and Contractor (“Relevant Persons”) Privacy Notice 1

Who is the Data Controller?

Precisions Castparts Corp. is a company registered in Oregon Unites States of America with its registered office at 4650 SW Macadam Ave, Suite 400, Portland, Oregon 97239. This privacy notice applies to Precisions Castparts Corp. and its subsidiary companies (“PCC”) which and to the extent process and store information from which Relevant Persons that are citizens of or located in the United Kingdom or European Union are identified or identifiable (“Personal Data”).

For company data protection registration details please contact your potential employer, employing, or engaging company (“Relevant PCC Company”).

Why do we use your personal information?

To verify your identity, process your application for employment, administer your contract of employment, manage our business, comply with our legal and regulatory obligations and for the purposes of record keeping, security, the prevention and detection of crime and management of legal risk. For more detail please see Appendix 1.

Our legal bases for using your personal information

Where necessary for the performance of your contact of employment or to take steps at your request prior to entering into such a contract, where necessary to comply with our legal obligations (for example as regards tax, health and safety and equal opportunities legislation) in accordance with our legitimate interests and where you give your consent. For special category Personal Data (for example relating to your health or criminal record (see below) our legal basis for processing include necessity for the purposes of carrying out employment, social security and social law obligations and your explicit consent.

What information about you do we use?

We may collect the following information about you:

  • information to identify you, your employment history and qualifications, your experience and performance, your bank details and other information you (or your third party representative(s)) provide to us with during the application process and your employment, or otherwise share publically;
  • information about you received from other employees, contractors or third parties;
  • CCTV images we obtain in the workplace (all areas covered by CCTV use are clearly signed);
  • Information you otherwise provide or produce in the course of your application and/or employment including any documents or communications made or websites accessed using our IT systems which may be monitored from time to time;
  • information about you obtained from third party organisations, including your previous employers or referees, the Disclosure and Barring Service and credit reference agencies (CRAs). The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at www.equifax.co.uk/crain.html; for the United Kingdom, or equivalent body in other jurisdictions;
  • information obtained from other public data sources which might include data from the electoral roll and public records including court judgments.

For more detail see Appendix 2.

When can we use or record sensitive information about you?

We may collect \"special categories\" of particularly sensitive Personal Data about you. This type of information requires higher levels of protection. It could include information about your ethnicity, religion, physical or mental health, trade union membership or other sensitive information from you. We may collect this information where you disclose it to us voluntarily or where we collect it as part of your employment. We may process this information where it is necessary for the purposes of complying with the law in relation to your employment (or law which is applicable as a result of your employment, such as our obligations under Health and Safety and Equality legislation). We may also process this information where you have provided your consent by volunteering this information to us. You have a right to withdraw your consent but this will not affect any processing which has already occurred.

Who may we share your information with?

We may share your information with:

  • our partners, agents, professional advisers or our third party service providers;
  • law enforcement agencies or regulatory bodies where we are required to do so;
  • other members within the PCC group of companies;
  • any purchaser or proposed purchaser of all or part of the PCC group or their assets, together with their professional advisors;
  • you or your third party representatives (in line with your rights); or
  • with other third parties where we believe, in good faith, that it is necessary to protect our rights, property, safety or reputation or the rights, property, safety or reputation of any of our clients or partners.

Can we change the purposes we process your information for?

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will only do so in compliance with laws.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Where is your information stored? Where can it be transferred?

The information we collect and hold about you will sometimes be transferred outside of the European Economic Area (the EEA), for example where it is accessed by PCC group company staff in the US. To ensure that your Personal Data is adequately protected we have put in place data transfer agreements in compliance with EU model contract clauses. If you require more information please contact us.

How long will your information be kept on file?

Where you apply for employment but are unsuccessful we will normally keep your data for up to 1 year. Where you are an employee we will keep your information during and after the end of your employment to the extent it is necessary for the protection of our legitimate interests, and longer where otherwise required by law.

Your rights

Right of access
You have a right to access the personal information we hold about you (subject to certain limitations).
Right of rectification
You can ask us to correct or update your information to ensure it is accurate and complete.
Right to erasure and right to restrict processing
You can ask us to stop processing and to delete your data in certain circumstances (for example where it is processed with your consent, or it is no longer necessary for us to process it).
Right to data portability
You have a right to ask us to provide you with information in a form that suits you, and/or to provide your information to a third party.
Right to object
You have a right to object to our processing of your information (in certain circumstances).
Rights: profiling and automated decisions
You have a right not to be subject to automated decisions which have a legal effect and to be protected by safeguards in respect of any profiling.

You can exercise the above rights by contacting us. Further information about your rights is also available from the United Kingdom ICO’s website (www.ico.org.uk), and from equivalent data privacy and protection governing bodies in other jurisdictions.

Contact and complaints

If you have any questions about this Privacy Notice, want to exercise your rights or make a complaint, please contact the Data Protection Coordinator or Human Resources Manager at your Relevant PCC Company in the first instance. You can also make a complaint to the ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113. www.ico.org.uk. In the United Kingdom or to the equivalent data privacy and protection governing bodies in other jurisdictions.

Profiling

We use profiling techniques to assist with recruitment for certain management roles.

Updates

Updates to this privacy notice will be made from time to time and notified to you by email, post, or notice board display where appropriate.


Appendix 1 – situations and purposes for which we may process your information

We may process your Personal Data for the following purposes:

  • Making a decision about your recruitment or appointment.
  • Determining the terms on which you work for us.
  • Checking you are legally entitled to work in the relevant jurisdiction.
  • Paying you and, if you are an employee, deducting tax and National Insurance contributions (or equivalent).
  • Providing contractual employment benefits to you.
  • Liaising with your pension provider.
  • Administering the contract we have entered into with you.
  • Business management and planning, including accounting and auditing.
  • Conducting performance reviews, managing performance and determining performance requirements.
  • Making decisions about salary reviews and compensation.
  • Assessing qualifications for a particular job or task, including decisions about promotions.
  • Gathering evidence for possible grievance, disciplinary or capability hearings including appeal hearings.
  • Making decisions about your continued employment or engagement.
  • Making arrangements for the termination of our working relationship.
  • Education, training and development requirements.
  • Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
  • Ascertaining your fitness to work.
  • Managing sickness absence.
  • Complying with health and safety obligations.
  • To prevent fraud.
  • To monitor your use of our information and communication systems to ensure compliance with our IT policies.
  • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
  • To conduct data analytics studies to review and better understand employee retention and attrition rates.
  • Equal opportunities monitoring.

Appendix 2 – what information we may collect about you

We may collect, store, and use the following categories of Personal Data 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 (please ensure you advise such next of kin or emergency contact details that you have provided us with their personal information).
  • National Insurance number or equivalent.
  • Bank account details, payroll records and tax/social security status information.
  • Salary, annual leave, pension and benefits information.
  • Start date.
  • Location of employment or workplace.
  • Copy of driving licence and/or passport or other identity documents.
  • Details about your personal or work vehicle and insurance.
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
  • 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 information obtained through electronic means such as swipecard /time recording records.
  • Information about your use of our information and communications systems, including your internet usage on PCC IT assets.
  • Photographs.
  • Sickness, health and medical records.

Annex 3 – Special categories of data: how and why we may use sensitive information about you

Lawful basis for processing and our obligations as an employer

”Special categories” of particularly sensitive Personal Data require higher levels of protection. We need to have further justification for collecting, storing and using this type of Personal Data. We may process special categories of Personal Data in the following circumstances:

  • In limited circumstances, with your explicit written consent.
  • Where we need to carry out our legal obligations and in line with our data protection policies.
  • Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme.
  • Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We will use your particularly sensitive Personal Data in the following ways:

  • We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
  • Where you suffer an accident or fall ill at work, we may use your information for the purposes of compliance with employment and health and safety law.
  • We will use information about your race or national or ethnic origin or religion, to ensure meaningful equal opportunity monitoring and reporting.
  • We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.

Do we need your consent?

We do not need your consent if we use special categories of your Personal Data in accordance with our procedures to carry out our legal obligations or exercise specific rights in the field of employment law and other relevant laws. Otherwise we will approach you for your written consent to allow us to process certain particularly sensitive data.

If we do so, we will provide you with details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Background checks and information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our legal obligations. We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we have your written consent. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.


1 In compliance with the General Data Protection Regulation (EU) 2016/679