Last updated: 31 Oct 2023 This Privacy Notice tells you how ALDRIDGES DMCC (“Aldridges”, “we” or “us”) process your personal data. It also describes your data protection rights, including a right to object to some of the processing which ALDRIDGES carries out. More information about your rights, and how to exercise them, is set out in the Your Choices and Rights section. We also may provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information. This Privacy Notice applies to ALDRIDGES employees and, where applicable, to contractors who provide services to ALDRIDGES.
What Personal Data We Collect We process the following types of personal data in connection with your employment.
• Contact and identifiers: such as your name, address, phone, email, gender, date of birth, home address, personal email address, personal phone number, employee ID number, work contact details (phone, email, and physical address).
• Identification information: such as your passport number, National Insurance Number, immigration status, nationality, information concerning your race and ethnicity (for diversity monitoring purposes).
• Financial information: bank account details for payment and taxation purposes.
• Family, Lifestyle and Social Circumstances Information: beneficiaries’ details in relation to life insurance or other benefits, emergency contacts, marital status, information about family members (name, date of birth, gender and national personal ID number) where necessary for the provision of applicable benefits, guarantees or relocation assistance.
• Information provided by or about you when we recruited you or when you apply for an internal promotion, as well as information supplied by third parties, including references. Background record checks (including criminal convictions checks) where necessary for your role at ALDRIDGES.
• Employment Related Information: job title, compensation, benefits, professional experience, education, performance history, training records, skills, in certain countries, religious belief, information concerning performance, career and succession plans, conduct and about violation of laws or breach of company policies, in certain countries, where permitted, details of professional registrations, and sanctions with professional bodies.
• Information concerning your career progression: such as information about your performance and career developments.
• Benefits and expenses related information: the benefits you register for, expense records (such as details of out of pocket expenses, corporate credit cards, company cars or private cars where an allowance is claimed and mobile phone costs), medical leave information, medical certificates, other documents required to confer special benefit status, such as information concerning pregnancy status and age of children, etc. where applicable, your use of company equipment and resources, travel preferences and information about your health and sickness leave.
• CCTV footage: we collect video footage to protect the safety and security of our facilities. More information on this can be found in the CCTV section of this Privacy Notice.
• Information concerning your use of IT tools: computer and connection information, including statistics on how you engage with our platforms, referral URL, IP address, unique device ID and web log information as well as information about your use of our electronic resources, such as computers and mobile devices we may provide to you.
• Any other information you submit to us (including during the course of any correspondence you may have with us): such as signatures, photographs, opinions, your location (if you choose to enable it on a company device) and any other information you provide.
• Sensitive information: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs;; genetic data, biometric data processed solely to identify a human being; healthrelated data; data concerning a person’s sex life or sexual orientation. On occasion, we receive personal data from third party sources, such as if we receive details of a certification or training you obtained, or where we receive feedback concerning your performance or a referral from a previous employer.
Why We Collect, Use and Store this Personal Data
We collect, use and store your personal data for the reasons set out below.
Where this is necessary for ALDRIDGES to administer your contract of employment or for services or in connection with services or benefits which you request from us.
• The administration of payroll and benefits, absences, compensation, and expense management.
• To allow you to access medical insurance, occupational health, retirement plans, stock plans, access to company cars and automotive insurance, and childcare benefits, where provided. Some benefits may require you to provide personal data concerning family members, partners or next of kin, in which case you must inform them before providing it to us.
• Managing and developing our personnel – for example, performance and talent management, training and leadership development, award recognition, employee surveys, marketing to employees and the administration of the employee rewards platform, including using aggregated data for analytics and reporting purposes.
• Making a decision about your recruitment or appointment and determining the terms on which you work for us.
• Maintaining the security and integrity of our facilities (including registering vehicle license plates in the RSCs to ensure the efficient operation of the car park), equipment and electronic platforms. This includes administering access rights, monitoring compliance with company protocols, and where permitted by local law and in accordance with relevant policies, for investigations and disciplinary actions.
• Publishing internal directories and providing other internal communications tools. This includes information which you provide for your internal company profile.
• Operation of any ethics or whistleblowing hotline which ALDRIDGES may run now or in the future. To analyse and monitor the diversity of the workforce in accordance with applicable laws. This includes, for example, compliance with Emiratisation laws.
Where necessary to comply with a legal obligation.
• Making deductions from payroll for tax and social security purposes and providing information to tax and social security authorities, as required by law.
• Managing statutory sick pay and maternity pay.
• Disclosures to law enforcement agencies or in connection with legal claims, health & safety compliance, regulatory, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation).
• Protecting our legal rights. This includes, but is not limited to, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements.
Where you have given consent. For example, we may ask for your permission to use your image in a company publication. Where we ask for consent, you are free to withhold or revoke it.
How We Share Your Personal Data
We might some of your personal data with other members of the ALDRIDGES group to administer and manage group functions, including to make systems available to employees, to manage supply chains and to assess your performance.
Your personal data will also be shared with companies providing services under contract to ALDRIDGES, such as training providers, help desk providers and IT hosting and/or IT maintenance providers.
Your personal data also will be shared with third party benefits providers, such as for the purposes of obtaining health or life insurance, childcare vouchers and other applicable benefits. Personal data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.
In the event that a ALDRIDGES business is sold or integrated with another business (in part or whole), your details may be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business / business unit. Likewise we may share your personal data if we outsource a function related to your employment.
CCTV To protect our facilities, assets and personnel, and to deter, detect, record and allow analysis of any type of incident, including malicious actions such as theft or vandalism, accidents, fires, floods and other emergency situations, ALDRIDGES has installed CCTV cameras outside the entrances to its premises.
ALDRIDGES recognises the need to balance an individual’s right to privacy with the need to comply with its legal obligations to ensure the safety and security of ALDRIDGES employees, customers, visitors and corporate assets. ALDRIDGES does not employ CCTV equipment in any working or private areas, such as restrooms, toilets or changing rooms. Where CCTV is deployed externally, ALDRIDGES will only capture images of public streets and buildings where permitted.
Only authorised personnel have permission to operate the CCTV systems and view the images, including security teams, human resources and appropriate management, internal and external legal advisors, and police, law and regulatory enforcement authorities.
Unless ALDRIDGES can demonstrate it is otherwise justified, ALDRIDGES will not deploy covert CCTV technology. Notice of CCTV filming will be provided in the vicinity of any recorded space.
Your Choices and Rights You have the right to ask ALDRIDGES for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machinereadable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to ALDRIDGES processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep. If you have unresolved concerns, you have the right to complain to the data protection authority in the country you reside, where you work or where we are located.
To exercise any of these rights, or to obtain other information you can get in touch with us using the details set out below.
We will generally retain your personal data for the length of your employment and for a period of 6 years thereafter. Certain employment records may be kept for shorter or longer periods in accordance with applicable legislation or our internal operational requirements. Detailed information about the retention periods applicable to your employment records can be found in our Retention Policy.
International Transfers [Your personal data will be processed in or accessed from jurisdictions outside the United Arab Emirates (“UAE”) by us and by some of the third parties to whom we share your personal data.] We rely on robust data transfer mechanisms, such as contractual clauses which include certain requirements and obligations with respect to data protection and information security to ensure that your data is safeguarded even when transferred outside of the UAE. For further information, including to obtain a copy of the documents used to protect your information, please contact us as described in the Contact Us section below.
Updates to this document This Notice may be updated periodically. We will update the date at the top of its first page accordingly and encourage you to check for changes that we have made, which will be available at OpsSupport@Aldridges- Group.com. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this Notice, as required by applicable law. Contact Us The data controller for your personal data will be ALDRIDGES. If you have questions about this Notice or wish to contact us for any reason in relation to our personal data processing, please contact us at OpsSupport@Aldridges-Group.com or feel free to discuss this with your relevant Human Resources Lead. Your Data Protection Responsibilities In the course of your employment with ALDRIDGES, you may receive or access personal data relating to ALDRIDGES customers, suppliers, business partners or other ALDRIDGES personnel. To the extent that you process any personal data in the course of your employment, you agree to only process such personal data in accordance with any policies or instructions related to the protection of personal data.