What is the purpose of this document?

Construct Id (the trading name of Universal Identity Limited) is a “controller” in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for an account with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the onboarding exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR).

Data protection principles

• We will comply with data protection law and principles, which means that your data will be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

The kind of information we hold about you

In connection with your application to create an account/profile with us, we will collect, store, and use the following categories of personal information about you:

The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications and any other project related data required for your access to a site, project or otherwise deal with any third party contractor.

• Any information you provide to us during your use if Our services.
• We may also collect, store and use the following types of more sensitive personal information:
• Information about your race or ethnicity, religious beliefs and sexual orientation.
• Information about your health, including any medical condition and/or disability.
• Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about applicants from the following sources:

• You, the applicant.
• Any labour or recruitment agency, which has supplied data to support your application or continued use of our service.
• Construction Skills Certification Scheme Limited, from which we collect the following categories of data: professional training and qualifications.
• Disclosure and Barring Service in respect of criminal convictions.
• The following data from third parties is from a publicly accessible source (i) right to work checks (ii) Companies House information.

How we will use information about you

We will use the personal information we collect about you to:

• Verify your skills, qualifications, and suitability for the work or project.
• Carry out background and reference checks, where applicable.
• Communicate with you about the Construct Id’s services and any services we believe are complimentary or relevant to your use of Construct Id.
• Keep records related to your connections and activities within the Construct Id network.
• Comply with legal or regulatory requirements.

It is in our legitimate interests to decide whether to accept your application since it would be beneficial to our business to allow your application and access the Construct Id network.

We also need to process your personal information to decide whether to enter into a contract with you.

Having received your application form, we will then process that information to decide whether you meet the basic requirements for your application to be progressed. If we decide to offer you an account with us, we will then carry out any reasonable verifications and checks we require before confirming your account has been successfully activated.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully or to take your application further.

How we use particularly sensitive personal information

We will use your particularly sensitive personal information in the following ways:

We will use information about your disability status to consider whether we or any third party needs to provide appropriate adjustments relating to our service or within the supply chain.

We will use information 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.

Information about criminal convictions

We envisage that we may process information about criminal convictions.

We will collect information about your criminal convictions history if a member of your network would like to offer you a role or work which is conditional on checks and any other conditions, such as references, being satisfactory. In the event that such credentials as DBS or equivalent criminal records checks are required, we shall be entitled to carry out a criminal records check in order to satisfy ourselves or any relevant third party that there is nothing in your criminal convictions history which makes you unsuitable for any specific role or site.

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

Automated decision-making

You will be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing

Why might you share my personal information with third parties?

We will only share your personal information with the following third parties for the purposes of processing your application and other users of the service in accordance with your acceptance of offers to join a project or supply chain or for any other users of Construct Id’s lawful or legal purposes. 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. We do not allow our third-party service providers to use your personal data for their own purposes unrelated to the Construct Id service. We only permit them to process your personal data for specified purposes and in accordance with yours or our instructions.

We may share your personal data within our group or with relevant external third parties such as our suppliers and we may transfer, store and process your personal data outside the UK. More detail can be found in our website privacy policy including details of our group companies and third parties.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, 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 in accordance with the terms of our services or 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.

Data retention

How long will you use my information for?

We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to accept your application to join the Construct Id service and if your application has been successful we will retain such data throughout the period of your active membership and for such period as is reasonable thereafter. We retain your personal information for that period so that we can show, in the event of a complaint or legal claim, that we have not discriminated against applicants on prohibited grounds and that we have conducted the application exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.

Rights of access, correction, erasure, and restriction

Your rights in connection with 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.

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 the Construct Id data processing officer in writing.

Right to withdraw consent

When you applied for your account, you provided consent on the date hereof to us processing your personal information for the purposes of the application exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact our data protection officer. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) who is responsible for data protection issues in the UK.