Data controller: One or more of The Abbey Limited, The Bull Hotel Limited, Rembrandt Hotel Limited, The Sir Christopher Wren Hotel Limited & Sarova Hotels Limited (“Sarova Hotels”)
Sarova Hotels collects and processes personal data relating to its employees to manage the employment relationship. Sarova Hotels is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does Sarova Hotels collect?
Sarova Hotels collects and processes a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number, date of birth and gender;
- the terms and conditions of your employment;
- details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with Sarova Hotels;
- information about your remuneration, including entitlement to benefits such as pensions or insurance cover;
- details of your bank account and national insurance number;
- information about your marital status, next of kin, dependants and emergency contacts;
- information about your nationality and entitlement to work in the UK;
- information about your criminal record;
- details of your schedule (days of work and working hours) and attendance at work;
- details of periods of leave taken by you, including holiday, sickness absence, family leave and other absences authorised or not, and the reasons for the leave;
- details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;
- assessments of your performance, including formal job chats, appraisals, performance reviews and ratings, performance improvement plans and related correspondence;
- information about medical or health conditions, including Covid-19 vaccination status and test results and whether or not you have a disability for which Sarova Hotels needs to make reasonable adjustments.
Sarova Hotels may collect this information in a variety of ways. For example, data might be collected through application forms, CVs or resumes; obtained from your passport, visa or EU settlement documents or other identity documents such as your national ID card and driving licence; from forms completed by you at the start of or during employment
; from correspondence with you; or through interviews, meetings or other assessments.
Sarova Hotels will collect your time & attendance data and facial image as part of your clocking in and out procedure.
Sarova Hotels may also collect personal data about you from third parties, for example by obtaining references from former employers.
Where Sarova Hotels seeks information about you from third parties, we shall ask you for your consent to do so.
Why does Sarova Hotels process personal data?
Sarova Hotels needs to process data to consider whether to enter into an employment contract with you and to meet its obligations under any such employment contract. For example, it needs to process your data to provide you with such an employment contract, to pay you in accordance with such an employment contract and to administer benefit, pension and insurance entitlements.
In some cases, Sarova Hotels needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee’s entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled.
In other cases, Sarova Hotels has a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows Sarova Hotels, among other matters, to:
- run recruitment and promotion processes;
- maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights;
- operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
- operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes;
- operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled;
- obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled;
- operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that Sarova Hotels complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled;
- ensure effective general HR and business administration;
- provide references for current or former employees; and
- respond to and defend against legal claims.
Some special categories of personal data, such as information about health or medical conditions, are processed to carry out employment law obligations (such as those in relation to employees with disabilities).
Who has access to data?
Your information may be shared internally, including with members of the Human Resources team, your line manager, managers in the business area in which you work, directors and IT staff if access to the data is necessary for performance of their roles.
Sarova Hotels shares your data with third parties in order to obtain pre-employment references from other employers, and obtain necessary criminal record checks for liquor licensing purposes. Sarova Hotels may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.
Sarova Hotels also shares your data with third parties that process data on its behalf, in connection with payroll, the provision of benefits, online training and employee engagement. Currently these third-party organisations are Fourth Hospitality for human resources data, rota scheduling, payroll, pensions management and employee engagement solutions; Wagestream for financial benefits; NEST and Aviva for pensions; Canada Life and AXA/PHC for insurances; Mapal OS (Flow Hospitality & Engagement) and High Speed Training for online training and employee engagement solutions; and McQuaig for recruitment and development purposes. From time-to-time training companies and insurance providers are reviewed and these companies may accordingly change.
Sarova Hotels does not transfer your data to countries outside the United Kingdom and European Economic Area.
How does Sarova Hotels protect data?
Sarova Hotels takes the security of your data seriously. Sarova Hotels has appropriate internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties or as otherwise required for the proper running of the business.
For how long does Sarova Hotels keep data?
Sarova Hotels will hold your personal data for the duration of your employment. The termination of an employment relationship does not mean that all records will be deleted. Following the termination of your employment, Sarova Hotels deletes data that it no longer requires. In most circumstances, the maximum periods for which your data is normally held after the end of employment are:
- seven (7) years after the end of the financial year to which they relate, for all payroll and tax records.
- seven (7) years for dates of employment and positions held, absence records, working time records, training records and accidents and health and safety matters, performance and disciplinary records.
- two (2) years after the image is obtained for facial images on time & attendance data
As a data subject, you have a number of rights. You can:
- make a “subject access request” which is a request to access and obtain a copy of your data on request;
- require Sarova Hotels to change incorrect or incomplete data or where appropriate to erase that data;
- request that image data collected through time & attendance be deleted
- exercise your “right to be forgotten” where appropriate;
- exercise your right of “data portability” where appropriate;
- object to the processing of your data where appropriate; and
- exercise your right to complain to the Office of the Information Commissioner.
In common with the majority of comparable hotel companies Sarova Hotels uses CCTV (Closed Circuit Television) recording equipment on its properties and the immediate environs. Sarova Hotels generally keeps records from these cameras for up to forty-nine (49) days. Sarova Hotels uses this equipment and these recordings for the reduction and investigation of crimes and unacceptable behaviour.
What if you do not provide personal data?
You have some obligations under your employment contract to provide Sarova Hotels with data. For example:
- You are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide Sarova Hotels with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.
- You have to provide certain information, such as contact details, details of your right to work in the UK and payment details to enable Sarova Hotels to enter a contract of employment with you.
Sarova Hotels does not make decisions relating to your employment based solely on automated decision-making. However, for some senior positions within Sarova Hotels you may be required to complete a behavioural profile and ability test, either in paper format or online, the results of which are taken into consideration when making recruitment decisions.
Sarova Hotels does not use Artificial Intelligence or facial pairing on images collected alongside time & attendance data.
- The examples included in this notice should not be taken as restricting the interpretation of the general statement in which they are given.
- The headings in this notice are for convenience only and should not be taken into account in the interpretation of this notice.
If you have a query about this Privacy Notice or our data protection practices you can contact us as follows.
- In the UK and rest of the world outside of EU:
- By email at [email protected]
By post at Sarova Hotels Data Protection Manager, 11 Thurloe Place, London, SW7 2RS.
In the EU:
- By email at [email protected]
- By post at Lutz Lambeck, EU Sarova Hotels Data Protection Manager, Eschersheimer Landstrasse 42, 60322 Frankfurt, Germany