Employment Policy UK

TOPPAN Digital Language Ltd. and TOPPAN Digital Language (UK) Ltd. 

Employment Recruitment Privacy Notice 


1.1 TOPPAN Digital Language Ltd, TOPPAN Digital Language (UK) Ltd., (“we”, “our”, “us”, “the Company”) are committed to protecting the privacy and security of your personal information.

1.2 This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the UK General Data Protection Regulation (UK GDPR) and Regulation (EU) 2016/679 (General Data Protection Regulation) (EU GDPR). It applies to all employees and workers and to any individual subcontractors to whom a copy of this notice is provided. In some cases it may apply to other individuals working within our business (such as secondees).  This notice does not form part of any contract of employment or other contract to provide services. We may update or amend this notice at any time. Where appropriate, we shall notify you of those changes by email or via Sage HR.


2.1 The Company is a “data controller”. This means that we are responsible for how we hold and use personal information about you.

2.2 We will comply with data protection law. This says that the personal information we hold about you must be:

2.2.1 Used lawfully, fairly and in a transparent way;

2.2.2 Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

2.2.3 Relevant to the purposes we have told you about and limited only to those purposes;

2.2.4 Accurate and kept up to date;

2.2.5 Kept only as long as necessary for the purposes we have told you about; and

2.2.6 Kept securely.


3.1 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).

Certain types of personal data require extra protection, such as information about a person’s health (“special categories” data).  Information about criminal convictions also requires additional protection.

3.2 We will collect, store, and use the following categories of personal information about you and the basis for processing each is identified below:

Data types To allow us to perform our contract with you To enable us to comply with a legal obligation To pursue our legitimate interests (or those of a third party)
Full name
Address and contact details
Personal Email Address
CV & Qualifications
Date of birth
Marital and civil partnership status and dependants
Recruitment information (including copies of right to work documentation for foreign nationals to work in a particular country, references and other information included in a CV or cover letter or as part of the application process).
Information acquired through reference and background checks
Information acquired through qualification checks  
Start date
Benefits information
Compensation history
Bonus percentage / arrangement
Location of employment or workplace
Passport copy  
Visa details  
Bank account details, payroll records and tax status information
Tax details /  P45 / coding notices
NI / Social security number
Next of kin details – name, address, relationship, telephone numbers
Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).
Performance information
Complaints, grievance and resolution documentation
Disciplinary information
Holiday records
Other leave records (including without limitation compassionate leave and family leave, pregnancy or maternity and paternity leave)
Contract amendments – pay rise, bonus, etc.
Pension beneficiaries
Study leave & support – letters, amendments, etc.
Information about your usage of our IT and communications systems, including IP addresses
CCTV Footage and other information obtained through electronic means such as swipe card records
Leaving date and reason for leaving
Information about offices held (e.g. directorships) whether in the Company or any third party

3.3 We may also collect, store and use the following more sensitive types of personal information:

To allow us to perform our contract with you To enable us to comply with a legal obligation To pursue our legitimate interests (or those of a third party)
Information about your sex, gender reassignment, race, religion and/or belief, sexual orientation
Information about your health, including any medical condition and/or disability, health and sickness records and accident information
Information about criminal convictions and offences.


4.1 We collect personal information about employees and workers through the application and recruitment process, either directly from candidates or sometimes (and after specific consent has been obtained from the individual) from former employers, employment agencies, credit reference agencies or other background check agencies. We will also collect information about you in the course of your working for us.


4.2 We will only use your personal information when the law allows us to. We will generally use the personal information set out in the table in section 3 for the following purposes:

4.2.1 To perform our contract with you;

4.2.2 To comply with a legal obligation; and/or

4.2.3 Where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.

4.2.4 To fulfil the purpose of the processing for which you have given your consent.

4.3 We may also use your personal information in the following (probably rare) situations:

4.3.1 Where we need to protect your interests (or someone else’s interests).

4.3.2 Where it is needed in the public interest.


5.1 The situations in which we will process your personal information are listed below. We have indicated in the table the purpose or purposes for which we are processing or will process your personal information.

To allow us to perform our contract with you To enable us to comply with legal obligations To pursue our legitimate interests (or those of a third party)
Making a decision about your recruitment or appointment.
In the UK for determining whether your engagement is deemed employment for the purposes of Chapter 10 of Part 2 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) and providing you with a status determination statement in accordance with the applicable provisions of ITEPA 2003.
Paying you and deducting tax and National Insurance / Social Security contributions.
Enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties.
Checking you are legally entitled to work in the country you will be employed in.
Conducting performance reviews, managing performance and determining performance requirements.
Making decisions about salary reviews and compensation.
Gathering evidence for possible grievance or disciplinary hearings.
Determining the terms on which you work for us.
Obtaining quotes for and/or providing the benefits to you.
Liaising with your pension provider and other benefits providers.
Administering the contract we have entered into with you.
Business management and planning, including accounting and auditing.
Assessing qualifications for a particular job or task, including decisions about promotions.
Making decisions about your continued employment/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
Ascertaining your fitness to work.
Managing sickness absence.
Complying with health and safety obligations.
Preventing fraud.
Monitoring your use of our information and communication systems to ensure compliance with our IT policies.
Ensuring network and information security.
Conducting data analytics studies to review and better understand employee retention and attrition rates.
Ensuring the building/workplace is secure.
Complying with our legal obligations to employees e.g. national minimum wage, family friendly rights.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.


6.1 The provision of personal data by you is voluntary, but necessary for the conclusion and execution of the employment contract. If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations.


7.1 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 which 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 for doing so.

7.2 We may process your personal information without your knowledge or consent where this is required or permitted by law.


8.1 In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will generally process this information are listed below:

8.1 .1 We will use information relating to absence, which may include sickness absence or family-related leaves, to comply with employment and other laws; and

8.1.2 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 including statutory maternity pay, statutory and contractual sick pay, and pensions.

8.2 We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full 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.

8.3 We do not need your consent where the purpose of the processing is to protect you or another person from harm or to protect your well-being and if we reasonably believe that you need care and support, are at risk of harm and are unable to protect yourself.


9.1 We envisage that we may hold information about criminal convictions.

9.2 We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. In particular, we may collect information about criminal convictions in the course of the recruitment process and during your employment in order for us to evaluate extraordinary risks to our company and other employees incurred by your employment. Where appropriate, we may collect information about criminal convictions as part of the recruitment process (with your consent) or we may be notified of such information directly by you in the course of you working for us.  We will use information about criminal convictions and offences for the purposes of determining whether to offer you employment and for the purposes of making decisions of your continued employment where appropriate.

9.3 We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.


10.1 We may have to share your data with third parties, including third-party service providers where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so

10.2 We require third parties to respect the security of your data and to treat it in accordance with the law.

10.3 Where data is transferred outside of the EEA we will do so under standard contractual clauses or binding corporate rules or any other acceptable method that ensures a protection of your data to the standard required within the EEA.

10.4 If your personal data is transferred by us outside the EEA, we will take all reasonable steps to ensure that adequate measures are in place to keep your personal data as secure as it is within the EEA and in accordance with this Privacy Policy.

10.5 Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents). The following activities are or are likely to be carried out by third-party service providers: payroll, pension administration, benefits broking and provision, expenses administration, business travel administration, banking, auditing and administration.

10.6 How secure is my information with third-party service providers?

All our third-party service providers 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.

10.7 What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulator or to comply otherwise with the law.

11. Transferring information outside the UK or the EU

11.1 We will transfer personal information we collect about you to our group companies and servers/hosting partners located in the UK, EU and USA. There are GDPR adequacy regulations in place in respect of the UK and EU but there are no GDPR adequacy regulations in respect of the USA. This means that the USA is not deemed by the UK and EU GDPR to provide an adequate level of protection for your personal information (except in limited circumstances) unless specific safeguards are put in place.

11.2 To ensure that your personal information does receive an adequate level of protection, we have put in place a data protection agreement which includes EU GDPR model clauses as well as UK International Data Transfer Agreement provisions governing the transfer of data between our corporate entities and we are only entering service agreements for hosting or other services with Supplier Parties outside the UK and EU where EU model clauses or an IDTA forms part of the contract.

12. If you require further information about this you can request it from privacy@toppandigital.com.


13.1 We have put in place measures to protect the security of your information. Details of these measures are available upon request from privacy@toppandigital.com.

13.2 Third parties will be required by us to only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

13.3 We have put in place appropriate security measures to protect your personal information and we limit access to your personal information on a need to know basis. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.


14.1 How long will you use my information for?

14.2 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, or reporting requirements. We will ordinarily retain information about employees and workers during the period for which you are working/performing services for us and thereafter for the period allowed by law.

14.3 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.


15.1 Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

15.2 Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

15.2.1 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

15.2.2 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

15.2.3 Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

15.2.4 Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

15.2.5 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

15.2.6 Request the transfer of your personal information to another party

15.2.7 Complain to the Information Commissioner’s office in the UK if you believe we have breached our obligations in respect of your data.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact privacy@toppandigital.com in writing.

15.3 No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

15.4 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

15.5 Right to withdraw consent

If you have provided your consent to the collection, processing and transfer of your personal information 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 Franziska Hardmeier on privacy@toppandigital.com.  If you inform us that consent is withdrawn, we will no longer process your information for the original purpose unless we have another legitimate basis for doing so.


We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact privacy@toppandigital.com


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