Version: April 2025

Privacy Notice for Employees, Workers and Contractors

The purpose of this notice

Cielo is committed to protecting the privacy and security of your personal information to safeguard your fundamental rights.

This privacy notice describes how we collect and use personal information collected about you during and after your working relationship with us, in accordance with the UK General Data Protection Regulation (UK GDPR), the EU GDPR and applicable privacy laws globally.

It applies to all employees, workers and contractors.

For this purpose, Cielo is a "controller." This means that we are responsible for determining the legal grounds informing how we hold and use your personal information.

This notice applies to current and former employees, workers and contractors. We may update this notice at any time, and we will publish an updated copy of this notice as soon as reasonably practical.

It is important that you read and retain this notice (as updated from time to time) so that you are aware of how and why we are using that information and what your rights are under the data protection legislation.

Data protection principles

We will comply with data protection law, which says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  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.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

The kind of information we hold about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the person's identity has been removed (anonymous data).

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health, sexual orientation, race, religious belief, union membership, political affiliation, biometric information or criminal convictions.

We collect, store and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers and personal email addresses.
  • Date of birth.
  • Gender.
  • Marital status and dependents.
  • CV, application form and interview notes.
  • Next of kin and emergency contact information.
  • Fiscal code as required by applicable laws (e.g., Social Security number or local equivalent).
  • Bank account details, payroll records and tax status information.
  • Salary, annual leave, pension and benefits information.
  • Start date and, if different, the date of your continuous employment.
  • Leaving date and your reason for leaving.
  • Location of employment or workplace.
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
  • Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).
  • Compensation history.
  • Performance information.
  • Disciplinary and grievance information.
  • CCTV footage and/or other information obtained through electronic means such as swipe card records collected for the purpose of ensuring security of the work environment.
  • Information about your use of our information and communications systems.
  • Photographs and videos.
  • Results of any required employment and tax status checks.

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

  • Information about your race or ethnicity, gender or gender identity, and sexual orientation.
  • Information about your health, including any medical condition and sickness records, including:
    • details of any absences (other than holidays) from work including time on statutory parental leave and sick leave.
    • where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.
  • Information about criminal convictions and offences will be collected as part of pre-employment vetting checks. This information will not be stored by Cielo once the checks have been completed.

How your personal information is collected

We collect personal information about employees, workers and contractors through the application and recruitment processes, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies. We will collect additional personal information during job-related activities throughout the period of you working for us.

How we use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to perform our obligations set out in the employment agreement we have entered into with you and/or the offer terms we have provided to you (“C”).
  2. Where we need to comply with a legal obligation (“LO”).
  3. Where it is necessary for our legitimate interests or those of a third party (provided always that your interests and fundamental rights do not override those interests) (“LI”).

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else's interests).
  2. Where it is needed in the public interest (or for official purposes) as required by applicable laws.

Situations in which we will use your personal information

The situations in which we will process your personal information are listed below:

  • Making a decision about your recruitment or appointment. [C], [LI]
  • Determining the terms on which you work for us. [C], [LI]
  • Checking you are legally entitled to work in the country where you are employed. [C], [LO], [LI]
  • Paying you and, if you are an employee or deemed employee for tax purposes, deducting tax and locally applicable social security contributions. [C], [LO], [LI]
  • Providing the following benefits to you: Private Medical Insurance and Medical Cash Plan. [C]
  • Enrolling you in a pension arrangement in accordance with our statutory automatic enrollment duties. [C]
  • Liaising with the trustees or managers of a pension arrangement operated by us (or any group company), your pension provider and any other provider of employee benefits. [C], [LI]
  • Administering the employment agreement and/or offer terms we have entered into with you. [C], [LI]
  • Business management and planning, including accounting and auditing. [C], [LI]
  • Conducting performance reviews, managing performance and determining performance requirements. [C], [LI]
  • Making decisions about salary reviews and compensation. [C], [LI]
  • Gathering evidence for possible grievance or disciplinary hearings. [C], [LI]
  • Making decisions about your continued employment or engagement. [C], [LI]
  • Making arrangements for the termination of our working relationship. [C], [LI]
  • Education, training and development requirements. [C], [LI]
  • Marketing and promotional activities. [LI]
  • Dealing with legal disputes involving you or other employees, workers and contractors, including accidents at work. [C], [LI]
  • Ascertaining your fitness to work. [C], [LO], [LI]
  • Managing sickness absence. [C], [LO], [LI]
  • Complying with health and safety obligations. [C], [LO], [LI]
  • To prevent fraud. [C], [LO], [LI]
  • To monitor your use of our information and communication systems to ensure compliance with our IT policies. [C], [LI]
  • To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution. [LO], [LI]
  • To conduct data analytics studies to review and better understand employee retention and attrition rates. [LI]
  • Equal opportunities monitoring. [LO], [LI]

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the employment agreement or offer terms 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 (such as to ensure the health and safety of our workers).

Change of purpose

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.

How we use sensitive personal information

Special categories of sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation, or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

  1. In limited circumstances, with your explicit consent.
  2. Where we need to carry out our legal obligations or exercise rights in connection with your employment.
  3. Where it is necessary to protect you or another person from harm.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Situations in which we will use your sensitive personal information

In general, we will not process particularly sensitive personal information about you unless it is necessary for performing obligations or exercising rights in connection with your employment.

The situations in which we will process your sensitive personal information in order to exercise rights and perform obligations in connection with your employment are listed below:

  • We will use information about your physical or mental health or disability status to:
    • ensure your health and safety in the workplace;
    • assess your fitness to work;
    • provide appropriate workplace adjustments;
    • monitor and manage sickness absence; and
    • administer benefits including statutory maternity pay, statutory sick pay, and pensions and permanent health insurance.
  • If you apply for an ill-health pension under a pension arrangement operated by us or any group company, we will use information about your physical or mental health in reaching a decision about your entitlement.

Other reasons we will use your sensitive personal information are as follows:

  • We will use information collected with your explicit consent about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation to ensure meaningful equal opportunity monitoring and reporting.
  • If we reasonably believe that you or another person are at risk of harm and the processing is necessary to protect you or them from physical, mental or emotional harm or to protect physical, mental or emotional well-being.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This is usually where that processing is necessary to carry out our obligations and provided we do so in line with our Data Protection Policy.

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. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you while you are working for us. We will not store this information itself. We will keep a record of the outcome for hiring purposes.

AI telephone screening

For some roles, during the preliminary stages of the recruitment process, Cielo operates a telephone screening process to pose some basic questions relating to a candidate’s suitability for a given role. This may occur prior to encouraging submission of a formal application or at formal interview stage.

This process may be carried out by an AI agent which will pose questions (pre-defined by a human resource involved in the recruitment process) and collect information.

Please note that the AI agent will not make any decisions over your suitability for a role and will only collect the essential information which will be reviewed by the recruiter effecting a decision.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the country in which we have collected it. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties 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.

Which third-party service providers process my personal information?

Third parties include third-party service providers carrying out the following activities: screening, SMS messaging services (opt-in only) solely used for the purpose of helping you schedule appointments and receive updates via SMS, payroll, pension administration, benefits provision, and administration.

We will share personal data regarding your participation in any pension arrangement operated by us with the trustees or scheme managers of the arrangement in connection with the administration of the arrangements.

How secure is my information with third-party service providers and other entities in our group?

All 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 and applicable law. 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.

Should you opt-in to SMS communications, we will not share this information with any third party except where necessary for enabling the functionality of tools sending communications about your job application. Data shared for this purpose includes your personal data, including your SMS opt-in or consent status as shared with third parties providing our messaging services, such as platform providers, phone companies and any other vendors delivering text messages on our behalf. Consent to send text messages is not purchased from third parties and needs to be given by you.

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 or on the termination of a client contract if the Transfer of Undertakings (Protection of Employment) (TUPE) laws (or local equivalent) apply. In this situation we will, so far as possible, only share anonymized 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 otherwise comply with the law. This may include making returns to tax authorities and disclosures to shareholders such as directors' remuneration reporting requirements.

International transfers of personal data

Individuals within the European Economic Area (“EEA”), Switzerland and the United Kingdom (“UK”) should be aware that recipients of their personal data, whether within the Group or external third parties (as mentioned in this notice), may be located in countries or territories which may not have adequate data protection laws equivalent to those in the EEA, Switzerland or the UK.

Where there is no Adequacy Decision allocated by the European Commission or the UK’s Information Commissioner’s Office, we leverage other mechanisms, such as Standard Contractual Clauses combined with an applicable transfer risk assessment to ensure adequate protection of your data in accordance with the EU and UK GDPR and other frameworks which may apply to the jurisdictions covered by our services.

UK-U.S., EU-U.S. and Switzerland-U.S. Data Privacy Framework

Cielo complies with the EU-U.S. Data Privacy Framework ("EU-U.S. DPF") and the UK Extension to the EU-U.S. DPF, and the Switzerland-U.S. Data Privacy Framework ("Swiss-U.S. DPF") as set forth by the U.S. Department of Commerce.

Cielo has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles ("EU-U.S. DPF Principles") with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

Cielo has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles ("Swiss-U.S. DPF Principles") with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.

If there is any conflict between the terms in this privacy notice and the EU-U.S. DPF Principles (including the UK extension to these) and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Cielo commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf.

Pursuant to the DPF Principles, Cielo acknowledges that we remain liable for the onward transfer of data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages. We may be required to release personal data in response to lawful requests by public authorities including to meet national security and law enforcement requirements.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Cielo commits to resolve DPF Principles-related complaints about our collection and use of your personal information.

EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Cielo at:

privacy.office@cielotalent.com

and/or

Data Protection Officer
Cielo Talent Management Limited
30a Great Sutton Street
London EC1V 0DU
United Kingdom

The Federal Trade Commission has jurisdiction over Cielo’s compliance with the DPF.

If you object to your data being transferred outside the EEA, please visit our Preference Center to advise us or email privacy.office@cielotalent.com.

Our Privacy Office strives to maintain up to date and relevant knowledge on the requirements for handling personal data across different jurisdictions.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available to current employees on the company intranet.

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

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Additionally, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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.

How long we will use your information for (data retention)

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. Details of retention periods for different aspects of your personal information are available in our Data Retention Policy which is available to current employees on the company intranet.

To determine the appropriate retention period for personal data, we consider:

  • The amount, nature and sensitivity of the personal data.
  • The potential risk of harm from unauthorized use or disclosure of your personal data.
  • The purposes for which we process your personal data and whether we can achieve those purposes through other means.
  • The applicable legal requirements.

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

Rights of access, correction, erasure and restriction

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.

Your rights in connection with your personal information

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

  • 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.
  • 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.
  • 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).
  • 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.
  • 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.
  • Request the transfer of your personal information to another party.

You can exercise your rights at any time regardless of the legal grounds on which your information is being processed. However, not all rights are “absolute” and some may therefore not be fulfilled. Please contact the Privacy Office in writing at privacy.office@cielotalent.com in connection with any of the above rights.

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 repeated on multiple occasions. Alternatively, we may refuse to comply with the request if it is determined to be manifestly unfounded and/or excessive.

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). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may 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 the Privacy Office at privacy.office@cielotalent.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection officer (DPO) and complaints

We have appointed a DPO to oversee compliance with this privacy notice and our data processing activities across Cielo. If you have any questions about this privacy notice or how we handle your personal information, please contact the Privacy Office at privacy.office@cielotalent.com.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), or the competent Data Protection Authority of the country where you are based with respect to data protection issues.