Employee privacy policy

Welcome to Bluecube’s Privacy Policy. Bluecube respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. This is the standard privacy policy that applies to the following Bluecube companies: 

• Bluecube Technology Solutions Ltd 
• Bluecube Cyber Security Solutions Ltd 

When we use “Bluecube”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant Bluecube company responsible for processing your data.  

This privacy policy describes how we collect and process your personal data during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR) and associated data protection legislation. 

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them. 

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). 

We collect and process various categories of personal data to manage your employment relationship effectively. The categories of personal data we may collect include, but are not limited to: 

• Identity Data includes first name, last name, signature 
• Contact Data includes home address, email address, emergency contact information and telephone numbers. 
• Employment Data includes job title, department, salary and compensation, work history and qualifications, performance evaluations, promotions and disciplinary records  
• Financial Data includes bank account and payment details, tax information and National Insurance Number and/or right to work 
• Benefits Data includes pension contributions and details, benefits enrolment and utilisation 
• Human Resources Data including employment contracts, your CV, references, leave requests and records, training and development history, attendance records and timekeeping information, workplace accommodations and health records (if applicable) 
• Communication Data includes emails, correspondence, and communication records related to your employment, your voicemails, or calls 
• Health and Safety Data includes accident reports and related documentation, occupational health assessments (if applicable) 
• Technical Data includes usernames and access credentials for company systems and applications, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use, network and system event logs, facility access logs 
• Profile Data includes your username and password, your interests, preferences, feedback, and survey responses. 
• Biometric Data includes fingerprint or facial recognition data for access control 
• Image Data includes photographs for employee profiles and identification, CCTV images for security and access control purposes 

We use different methods to collect data from and about you, including through: 

• Direct Interactions: You may provide personal data directly to the company during the onboarding process, through forms, applications, or other interactions. For example, when you fill out your employment application, update your personal information, or communicate with HR. 
• Company Systems and Applications: Personal data is often collected when you use company systems, applications, and tools. For example, when you log in to your company email account or use software for work-related tasks. 
• Human Resources (HR) Processes: You may provide employment-related data as part of standard processes, including data related to performance evaluations, promotions, and disciplinary records. 
• CCTV and Building Access Control: Personal data may be collected through CCTV cameras and access control systems when entering company premises or specific areas within the workplace. 

• Technical Data: Technical data, such as device information, network information, and system logs, is typically collected automatically as you use company-provided devices and access company networks and systems. 
• Email Communication: Information related to email communication, including email metadata, is generated, and collected as part of the normal functioning of email systems. 
• Health and Safety Records: Health and safety data may be collected through incident reports, risk assessments, or health-related assessments, if applicable to your role. 
• Benefits Enrolment: Personal data related to benefits, such as pension contributions and insurance coverage, is collected during benefits enrolment processes. 

We process your personal data for the following specific and detailed purposes: 

Employment Management: 

• Payroll Processing: We process your personal data to manage your salary, compensation, and benefits, ensuring accurate and timely payment. 
• Benefits Administration: Personal data is used to administer employee benefits such as pension plans, insurance coverage, and other perks or allowances. 
• Performance Management: We collect and analyse your data as part of our performance management processes, including performance evaluations, promotions, and career development planning. 
• Workforce Planning: Your employment details help us plan for future workforce needs, including recruitment, training, and succession planning. 

Communication: 

• Work-Related Communications: We use your contact information to send work-related communications, including emails, notifications, and announcements related to your employment, projects, or company updates. Technical data related to email communication helps ensure efficient email routing, delivery, and management. 

Compliance: 

• Legal and Regulatory Compliance: Your personal data is processed to ensure compliance with applicable employment laws, tax regulations, and other legal requirements, including the collection of necessary tax and National Insurance data. 
• Contractual Obligations: We process data to fulfil our contractual obligations with you, such as providing employment-related benefits and adhering to the terms of your employment contract. 

Security 

• Access Control: We use access controls and collect access data to secure our premises, information systems, and sensitive data. This includes biometric data for access control where applicable. 
• CCTV Monitoring: CCTV images are used for security and access control purposes to safeguard our facilities, personnel, and assets. 
• System Maintenance and Security: Technical data helps us monitor and maintain the security and performance of our information systems, ensuring they are operational and secure. 
• Software and Application Management: It aids in managing software licenses, updates, and access permissions to ensure compliance with licensing agreements and security policies. 

Health and Safety 

• Health and Safety Records: Data is processed to maintain health and safety records, conduct risk assessments, and ensure a safe working environment for all employees. 
• Occupational Health Assessments: When necessary, we may process health-related data for occupational health assessments, accommodations, or related purposes, with your consent or as required by law. 

Benefits Administration 

• Pension Management: We use your data for the administration of pension contributions, calculations, and retirement planning. 

• Insurance Coverage: Personal data is processed to manage employee insurance coverage, including claims processing and beneficiary information. 
• Benefits Enrolment: We process data during benefits enrolment periods to ensure that you receive the benefits you are entitled to. 

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

As part of our commitment to transparency, we want to inform you about circumstances in which your personal data may be disclosed to other entities, including companies within our group. We take your privacy seriously and ensure that any disclosures of your personal data are made in accordance with applicable data protection laws and regulations. 

We may share your personal data with the parties set out below for the purposes set out above: 

• Other Bluecube and Ekco Group Companies: We may share your personal data with other companies within our corporate group for legitimate business purposes, including those related to employment management and administrative efficiency. These group companies may be located within or outside the United Kingdom 
• External Service Providers: We may engage external service providers (sub-processors) to assist in certain data processing activities, such as payroll processing, benefits administration, and software support. These providers are carefully selected and contractually bound to comply with data protection laws and maintain the security of your data. 
• Regulatory Authorities: We may disclose personal data when required by applicable laws or regulations, including disclosures to government or regulatory authorities for compliance purposes. 
• Legal and Financial Advisors: Personal data may be shared with legal and financial advisors when necessary for legal proceedings, contract negotiations, or financial transactions. 
• Security and Investigations: In the interest of security, personal data may be shared with law enforcement or investigative agencies in cases of suspected fraud, security breaches, or other unlawful activities. 
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have implemented a comprehensive set of technical, organisational, and procedural measures to ensure the confidentiality, integrity, and availability of your personal data. Below, we provide detailed information about the data security measures we have put in place: 

Access Controls 

• User Authentication: Access to your personal data is restricted to authorised personnel only. Users are required to use strong, unique passwords or other secure authentication methods. 
• Role-Based Access Control: We employ RBAC to ensure that employees have access only to the data and systems necessary for their job roles. 
• Multi-Factor Authentication (MFA): For systems and applications containing sensitive data, we require the use of MFA to provide an additional layer of security. 

Encryption 

• Data in Transit: We use industry-standard encryption protocols (e.g., TLS/SSL) to encrypt data when it is transmitted over networks, ensuring that it remains confidential during transmission. 
• Data at Rest: Sensitive data stored on servers and databases is encrypted to protect against unauthorised access, even in the event of physical server compromise. 

Security Assessments and Audits 

• Regular Assessments: We conduct regular security assessments, including penetration testing and vulnerability scanning, to identify and address potential weaknesses in our systems and applications. 
• External Audits: We are certified to ISO 27001:2013 and engage external security experts to conduct audits and assessments of our security controls, ensuring we meet industry best practices. 

Employee Training and Awareness 

• Data Protection Training: All employees receive training on data protection policies, procedures, and best practices to ensure they understand their responsibilities in safeguarding personal data. 
• Phishing Awareness: Regular phishing awareness campaigns help employees recognize and report phishing attempts, enhancing overall security. 

Incident Response and Breach Notification 

• Incident Response Procedures: We maintain incident response procedures to promptly address security incidents, including data breaches. This includes containment, investigation, and communication procedures. 
• Breach Notification: In the event of a data breach with a risk to your rights and freedoms, we will notify you and the relevant regulatory authorities as required by law. 

Physical Security 

• Access Controls: Physical access to data centres and server rooms is restricted to authorised personnel only. Access is logged and monitored. 
• Video Surveillance: Security cameras are in place to monitor and record access to sensitive areas. 

Data Backup and Recovery 

• Regular Backups: Data is regularly backed up to secure, offsite locations to ensure data availability and disaster recovery. 
• Testing: Backup and recovery procedures are regularly tested to ensure data can be restored accurately and efficiently in case of data loss. 

Network Security 

• Firewalls: We use firewalls and intrusion detection systems to protect our network from unauthorised access and malicious activity. 
• Security Patching: Systems and software are kept up-to-date with security patches and updates to mitigate vulnerabilities. 

Secure Disposal 

• Data Destruction: When personal data is no longer needed, we have secure processes for its disposal, including shredding physical documents and securely wiping electronic media. 

Security Monitoring 

• Security Operations Centre (SOC): We maintain a SOC to monitor network and system activity, detect and respond to security incidents in real-time. 
• Logging and Alerting: Logs from various systems are collected, analysed, and retained to identify and investigate any suspicious or unauthorized activities. 

These data security measures are continually reviewed, improved, and aligned with industry best practices and applicable data protection laws and regulations to ensure the ongoing protection of your personal data.  

We may engage external service providers (sub-processors) to assist in processing your personal data for specific purposes. These sub-processors are carefully selected and contractually bound to adhere to data protection laws and provide appropriate safeguards for your data. 

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

Under certain circumstances, by law you have rights under data protection laws in relation to your personal data, as follows: 

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
• Request the transfer of your personal data to you or a third party. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
• Withdraw your consent to the processing. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact enquiries@bluecube.tech. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. 

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact enquiries@bluecube.tech. 

If you have any questions or comments regarding how we handle your personal data, please contact us at: 

• enquiries@bluecube.tech  

• Data Protection, Norfolk House, 106 Saxon Gate West, Milton Keynes, United Kingdom, MK9 2DN