Part 4/11: Privacy Notice For Sub-contracted Self-employed Drivers

In accordance with the general data protection regulation (GDPR), we have implemented this privacy
notice to inform you of the types of data we process about you. We also include within this notice
the reasons for processing your data, the lawful basis that permits us to process it, how long we
keep your data for and your rights regarding your data.
This notice applies to former and current sub-contractors (self-employed drivers).

    Under GDPR, all personal data obtained and held by us must be processed accordingly to set
    the core principles. In accordance with these principles, we ensure that:

A) Processing is fair, lawful and transparent
B) Data is collected for specific, explicit, and legitimate purposes
C) Data collected is adequate, relevant and limited to what is necessary for the purpose
of processing
D) Data is kept accurate and up to date. Data which is found to be inaccurate will be
rectified or erased without delay,
E) Data is not kept for longer than necessary for its given purpose
F) Data is processed in a manner that ensures appropriate security of personal data
including protection against unauthorised or unlawful processing, accidental loss,
destruction or damage by using appropriate technical or organisational measures
G) We comply with the relevant GDPR procedures for international transferring of personal data.

    We keep several categories of personal data on self-employed drivers we use in order to
    carry out effective and efficient processes. We keep this data in a personal file relating to
    each driver and we also hold the data within our computer systems, for example, our rota

Specifically, we hold the following types of data:

A) Personal details such as name, address, address history and phone numbers
B) Name and contact details of your emergency contact
C) Your photograph
D) Your gender, marital status, information of any disability you have or other medical information
E) Right to work documentation
F) Information on your race and religion for equality monitoring purposes
G) Information gathering via the recruitment process such as that entered into a CV or included in a CV cover letter
H) Signed contractor and health and safety forms
I) Insurance certificates
J) Proof of address
K) Mothers first and maiden name
L) Email address
M) National insurance numbers
N) Bank account details
O) Tax and VAT codes
P) Driving licence
Q) Criminal convictions
R) Drug and alcohol test results
S) Information relating to your work with us, including:

  1. Performance related data
  2. pay rates
  3. planned/historical work
  4. details of formal and informal proceedings involving you from contracts worked on
  5. external training modules undertaken

T) CCTV footage
U) Building access card records
V) IT equipment use including telephones and internet access.

    You provide several pieces of data to us directly during the recruitment period and
    subsequently upon the start of your contracted work and on-going.
    In some cases, we will collect data about you from third parties, such as contractors you are
    conducting work for, DVLA, ABBOT.
    Personal data is kept in files or within the company’s HR and IT systems.
    The law on data protection allows us to process your data for certain reasons only. In the main, we
    process your data in order to comply with a legal requirement or in order to effectively manage the
    contract we have with you, including ensuring you are paid correctly.

The information below categorises the types of data processing we undertake and the lawful basis
we rely on.


    Activity requiring your data Lawful basis

Carry out the contract that we have entered
with you e.g. using your name, contact details,
address history and information involving you
(such as DBS/DVLA checks, drug and alcohol
tests) to assess on going eligibility to work on
the contract

Performance of the contract

Ensuring you are paid

Performance of the contract

Carrying out checks in relation to your right to
work in the U.K

Legal obligation

Making reasonable adjustments for disabled

Legal obligation

Making decisions about pay rates

Our legitimate interests

Ensuring efficient administration of
contractual benefits to you

Our legitimate interests

Effectively monitoring both your conduct,
including timekeeping and attendance,
your performance and to undertake
procedures where necessary

Our legitimate interests

Maintaining comprehensive up to date records
about you to ensure, amongst other things,
effective correspondence can be archived and
appropriate contact points in the event of an
emergency are maintained

Our legitimate interests

Assessing training needs

Our legitimate interests

Dealing with legal claims made against us

Our legitimate interests

Preventing fraud

Our legitimate interests

Ensuring our administrative and IT systems are secure and robust against unauthorised access

Our legitimate interests

Sharing with third parties to support/ assess
your on-going work with us (section H below)

Performance of the contract


    Special categories of data that we hold are data relating to your health
    We are aware of the requirement to ensure your data is protected against accidental loss or
    disclosure, destruction and abuse. We have implemented process to guard against this.
    We only keep your data for as long as we need it for, which will be at least for the duration
    of your work with us though in some cases we will keep your data for a period after your
    work has ended. Some data retention periods are set by law. Retention periods can vary
    depending on why we need your data, as set out below.
   Record Statutory Retention Period

Pay rates (including bonuses)

6 Years

Worked hours

2 years after they are made


Recommended Retention Period

Assessments under health and safety
regulations and records of consultations with
safety representatives and committees


HMRC approvals


Driver files, training records (personal data, ID
records, application forms, contract)

6 years after end of end of work

Performance data

6 years after end of end of work

Payment/invoicing and days worked records

6 years after end of end of work

Driver drug and Alcohol test result

6 years after end of end of work

DBS checks

6 years after end of end of work

Van hire records/ insurance documents

6 years after end of end of work



Automated decision-making means making decisions about you using no human involvement e.g.
using computerised filtering equipment. No decision will be made about you solely based on
automated decision making
(where a decision is taken about you using an electronic system without human involvement)
which has a significant impact on you.


You have the following rights in relation to the personal data we hold on you:
a) The right to be informed about the data we hold on you and what we do with it;
b) The right of access to the data we hold on you. More information on this can be found in th
section headed “access to data” below and in our separate policy subject access request”;
c) The right for any inaccuracies in the data we hold on you, however they come to light, to be

Where you have provided consent to our use of your data, you also have the right to withdraw
that consent at any time. This means that we will stop processing your data, to this you will have to email us and notify us. You can withdraw the consent you are giving on this form at any time.
You can do this by emailing at


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Signed by Umair Malik
Signed On: 08/06/2021

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Document name: Part 4/11: Privacy Notice For Sub-contracted Self-employed Drivers
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14/09/2020 4:32 pm BSTPart 4/11: Privacy Notice For Sub-contracted Self-employed Drivers Uploaded by Umair Malik - IP