Last Updated: 22 April 2024
This privacy notice (Notice) explains how House 337 Limited and its associated Brands (we, our, us, House 337 Limited) processes the personal data of staff including workers such as casual workers, agency workers, contractors, interns, volunteers, those workers we employ via our chosen employer of record partners and protective staff such as job applicants. It also explains your rights under data protection legislation.
Please note that any references to "employment" or “staff” are not intended to imply or confer any employment rights to non-employees.
This Notice applies alongside any other information House 337 Limited provides about a particular use of personal data, for example when collecting data via an online or paper form.
If you are an employee based in California, please see our “Privacy Notice for the Collection for California Employees and Applicants”.
For the purposes of any applicable data protection laws in England and Wales, including the Data Protection Act 2018 (DPA) the UK General Data Protection Regulation (UK GDPR) and General Data Protection Regulation EU 2016/679 (EU GDPR), House 337 is the data controller of your personal data. House 337 has appointed a Data Protection Officer, who can be contacted via:
We may collect your personal data in a number of ways, for example:
We may collect the following types of personal data about you (and your family members and 'next of kin', where relevant):
Contact and communications information, including:
Biographical, educational and social information, including:
Financial Information, including:
Work Related Information, including:
Online Identifiers, including:
Where this is necessary for your employment or other engagement to work for us, we may also collect special categories of data and information about criminal convictions and offences, including information:
For employees that reside in California please see Schedule 1:United States of America where we provide a fuller explanation the definition of special categories data under the CCPA/CPRA
Subject to applicable law, your personal data may be processed by us for the following purposes:
Automated Decision Making and Profiling.
Your data will not be subject to automated decision making of profiling save for the following exceptions:
In the case of Chatbots that are built in house you will always receive a “just in time” notice, that is to say, a chatbot specific privacy notice when you first open the instance. This notice goes into more detail in relation to how to process the data for this processing activity.
Ongoing management
Absence Management and Health and Safety
Compliance Monitoring, Security and Systems Use
Termination of Employment and Managing Post-Employment Relationships
In addition to what is set out above we process special categories of personal data for the reasons set out below. We will process this data on the basis that such processing is necessary to carry to meet our obligations under the law andto exercise rights (both yours and ours) in relation to your employment.
In particular we process the following types of special category personal data for the following reasons:
Please note that if we process your special categories data in order to promote EDI in the workplace or to provide information to regulators, governing bodies or professional bodies to which you or the Brand you work for is a member, we will only ever provide aggregate data or data that does not identify you as an individual. For more information, please contact your HR department or The Data Protection and Privacy Office.
Every time we process personal data we must have a legal basis upon which to rely.
We will only collect, use and share your personal information where we are satisfied that one or more of the following legal bases apply:
1. Performance of Contract
The processing is necessary for the performance of a contract to which you are a party or in order to take steps, at your request, prior to entering into such a contract, for example collecting bank details to pay your salary or processing information to provide you with the contractual benefits to which you are entitled.
2. Legal and Regulatory Obligation
The processing is necessary for compliance with a legal obligation or regulatory obligation to which we are subject such as transferring personal data to local tax authorities, providing up to date background checks on certain categories of employees for example if we have an FCA regulated client who requires this check as part of their legal and regulatory obligations, avoiding unlawful termination, meeting statutory records keeping requirements or in order to comply with any requests from the FCA or other regulators as they may apply to House337 Limited.
3. Legitimate Interest
The processing is necessary for the legitimate interests pursued by Next15 or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information. When we use legitimate interest as our legal basis for processing your information we conduct an assessment in order to risk assess our activities. Our legitimate interests include our interests in running House 337 Limited in a professional sustainable manner, in accordance with all relevant legal and regulatory requirements and in line with industry best practice.
The processing is based on your consent. Where consent is required for the processing in question, it will be sought from you separately to ensure that it is freely given, informed and that we can clearly demonstrate that you consent was given to us via an affirmative action on your part.
Information regarding such processing will be provided to you at the time that consent is requested. You should be aware that it is not a condition or requirement of your employment to agree to any request for consent.
The processing is necessary in order to protect an individual’s vital interests in circumstances where there may be a life-threatening accident or illness as set out above.
If you have any queries regarding the legal basis for processing your personal data please contact the Data Protection and Privacy Office.
You may be asked to provide House 337 Limited with details of criminal convictions where your role requires a DBS check. We will only use the criminal convictions data for the purpose for which it was collected and it will only be retained for a limited period with the upper limited being 6 months in line with legal and regulatory guidelines.
If we are required by law to conduct criminal background checks, the lawful basis upon which we will rely is that processing is necessary for the purposes of fulfilling our or our clients’ obligations under employment, social security and social protection law and the condition under schedule 1 part 1(1) of the Data Protection Act 2018 has been met. Further information can be found within our Special Categories Data and Criminal Offence Data Processing Policy.
If you would like a copy of this policy document please contact the DataProtection and Privacy Office.
We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
If your engagement with House 337 Limited has been facilitated by one of our Employer of Record partners, then please ensure that you have also read their Privacy Notice in order to understand how they will process your personal information as they are a separate legal entity. If you require any help in understanding your rights under their notice please contact the Data Protection and Privacy Office.
For the above purposes, personal information may be transferred within or outside of the jurisdiction where you are employed, perform work or where you reside, either within our Group or to third parties, including, but not limited to:
House337 Limited may also disclose personal information to a third party where it is necessary to do so in order to protect or pursue our legitimate interests (ensuring this is proportionate and limited to information which is strictly necessary for the purpose of the processing activity). This may include, but not be limited to, disclosure to a party with whom we are in negotiation for the sale or transfer of a business, assets or services. House 337 Limited will take appropriate steps to ensure that the recipient of personal information in such circumstances puts in place an adequate level of protection for such personal information in accordance with applicable legal requirements.
If you would like further information in relation to third parties that we share your data with please contact the Data Protection and Privacy Office.
How secure is my information with third-party service providers and other entities within our group?
All of our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
International data transfers
There may be circumstances where House 337 Limited shares or discloses data out with the jurisdiction where you are employed, perform work or where you reside in relation to the provision of IT infrastructure or other professional services.
In these circumstances, and where applicable, your personal data will only be transferred on one of the following bases:
Please see Schedule 1 for Country Specific Information.
We will retain your Personal Data for as long as is reasonably necessary for the purposes explained in this Notice. This will usually be the period of youremployment or other contract with us plus the length of any applicable statutory limitation period following your departure, although some data, such as pension information, may need to be kept for longer. We may keep some specific types of data, for example, tax records, for different periods of time, as required by law and in line with our HR retention schedule.
In some cases we may also retain your Personal Data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your relationship with us. Where your Personal Data is no longer required we will ensure it is either securely deleted or stored in away that no longer identifies you.
If you would like further details regarding our retention periods please contact the Data Protection and Privacy Office.
Under data protection legislation you have the following rights:
Please note that the above rights are not absolute, and requests may be refused where exceptions apply. Please see Schedule 1 for Country Specific Information.
If you have any questions about these rights please contact the Data Protection and Privacy Office.
If you have any queries about this privacy notice or how we process your personal data, if you would like to make a complaint or if you wish to exercise any of your right please contact the Data Protection and Privacy Office at [email protected] or in writing to:
The Data Protection and Privacy Office,
60 Great Portland Street,
London,
W1W 7RT
If following such referral, you are still not satisfied with how your personal data is used by House 337 Limited you can make a complaint to the Information Commissioner (www.ico.org.uk).
If following such referral, you are still not satisfied with how your personal data is used by House 337 Limited you have the right to complain. Please see Schedule 1 for Country Specific Information.
House337 Limited will update this Privacy Notice from time to time. Any substantial changes that affect your rights will be provided to you directly as far as is reasonably practicable.