Agency Worker Data Policy
360 Talent London Ltd needs to collect and hold certain personal data about you in connection with your registration and assignments as an agency worker. We are committed to handling that data securely, transparently, and in compliance with UK data protection law, including the UK GDPR and the Data Protection Act 2018.
This policy explains what data we collect, why we collect it, how we use and protect it, and what your rights are. It applies to all current and former agency workers and applicants.
Key Points
• Your data is handled securely and confidentially at all times.
• We will always have a lawful basis for processing your data.
• Your data will not be retained for longer than necessary.
• You have the right to access, correct, or request deletion of your personal data.
• Breaches of data protection obligations may result in removal from assignment.
What Personal Data We Hold
We collect and process the following categories of personal data:
• Identity and contact information - name, address, date of birth, telephone number, email address
• Right to work documents - passport, visa, or other eligibility evidence
• Financial and payroll information - bank details, National Insurance number, tax information
• Emergency contact details
• Assignment and attendance records - shifts worked, timesheet data, lateness or absence
• Conduct and performance records – general performance feedback, any warnings, concerns, or removal from pool
• Health and disability information - where voluntarily disclosed or relevant to role suitability and reasonable adjustments
Where Your Data Comes From
We collect personal data from the following sources:
• Directly from you - during registration, onboarding, and the course of your assignments
• Hirers (clients) - attendance records, conduct concerns, or feedback relevant to assignments
• Payroll providers (Brookson Solutions) - pay and financial processing data
• Legal bodies - such as HMRC, in connection with tax and National Insurance obligations
Why We Process Your Data
UK data protection law requires us to have a lawful basis for processing your personal data. We rely on one or more of the following:
• Performance of your contract - to manage your assignments, process your pay, and meet our obligations to you
• Legal obligations - to comply with statutory duties including right to work checks, tax, and National Insurance
• Legitimate interests - to operate our business effectively, manage conduct and performance, prevent fraud, ensure system security, and handle legal claims
• Consent - in limited circumstances where no other lawful basis applies. Where we rely on consent, you may withdraw it at any time. Withdrawing consent will not affect processing already carried out on other lawful grounds.
Who Your Data is Shared With
Your personal data is only shared where there is a legitimate reason to do so. Recipients may include:
• Hirers (clients) - to facilitate your assignment, including your name, contact details, and attendance records
• Our payroll provider - for processing pay and statutory deductions
• HMRC - for tax and National Insurance purposes
• Our HR Consultant - where HR support is required
• Legal or regulatory bodies - where required by law
We do not sell your personal data. We do not transfer your data outside the UK or European Economic Area without appropriate safeguards in place.
Health and Sensitive Information
If you disclose health, disability, or other sensitive information to us, this will be treated with additional care. It will only be used for the purposes for which it was shared. This is typically to assess role suitability, make reasonable adjustments, or administer sickness-related entitlements. It will only be shared with those who need it.
How Long We Keep Your Data
We retain personal data only for as long as is necessary for the purpose for which it was collected, taking into account any legal or regulatory requirements. The table below sets out our standard retention periods.
Your Rights
Under UK data protection law, you have the following rights in relation to your personal data:
• Right of access - you may request a copy of the personal data we hold about you (a Subject Access Request)
• Right to rectification - you may ask us to correct any inaccurate or incomplete data
• Right to erasure - you may request deletion of your data where we no longer have a lawful basis to retain it
• Right to object - you may object to processing based on legitimate interests
• Right to restrict processing - you may ask us to limit how we use your data in certain circumstances
To exercise any of these rights, please contact us at tempshr@360talentlondon.com. We will respond within one calendar month.
Data Security
360 Talent London takes the security of your personal data seriously. We use appropriate technical and organisational measures to protect your data against unauthorised access, loss, or destruction. Where data is shared with third parties such as payroll providers, we require them to maintain equivalent standards of security.
If you believe your personal data has been mishandled or you have a concern about how we have used your information, please contact tempshr@360talentlondon.com in the first instance.
Automated Decision-Making
We do not make decisions about you solely by automated means where those decisions would have a significant effect on you. All material decisions involving your personal data involve human review.
Complaints
If you are not satisfied with how we have handled your personal data, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):
Website: https://ico.org.uk
Telephone: 0303 123 1113
Compliance
All agency workers are expected to treat any personal data they encounter during an assignment, whether relating to colleagues, clients, or customers, with discretion and in accordance with data protection principles. Any misuse of personal data may result in immediate removal from assignment and, where appropriate, referral to the relevant authorities.
This policy is subject to periodic review.
