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Types of data and how we use it

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  1. Recruitment
  2. HR Functions
  3. Employment Functions
  4. Colleague Engagement
  5. Day to day activities
  6. Miscellaneous

Recruitment

Examples

  • Contact information
  • Personal identifiers
  • Emergency contact details
  • Bank account details

Purpose

  • To set up your accounts and system access
  • To ensure your salary is paid on time
  • So we can contact your nominated contact in the event of an emergency
  • So we can set up your pension
  • We do this in order to perform our contract with you

Examples

  • Your employment history
  • Any training you’ve undertaken or qualifications achieved (at StepChange or prior to your employment)
  • Any information you provide as part of your application
  • Your contact details

Purpose

  • To review your application and update you on its progress
  • To arrange any interviews or assessments

We do this because we have a legitimate interest to carry out recruitment activities.

Examples

  • Right to work checks
  • CIFAS checks
  • Disclosure and Barring Service (DBS) checks

Purpose

  • To ensure you have the right to work in the UK
  • To ensure your suitability for the role

We do this in order to comply with the law.


HR Functions

Examples

  • Your name
  • Your work email address
  • Your job title

Purpose

  • To maintain our employment records and our global address directory

We do this because we have a legitimate interest to maintain our employment records.

Examples

  • Your StepChange career history, including current and previous roles
  • Your progress through a StepChange academy (if your job requires one)
  • Records of any apprenticeship you attend
  • Any external or internal training you receive
  • Our internal leadership programme
  • Your Insights profile

Purpose

  • To monitor the progress of your career
  • To ensure you have the training you need to perform your job
  • To ensure that any legally required training is completed
  • To support you in your career development

We do this because we have a legitimate interest to develop our colleagues. In some cases we do this to comply with the law.

Examples

  • Records of annual leave
  • Records of any sickness absence
  • Records of any other absence, including maternity and paternity leave, adoption leave, or sabbaticals

Purpose

  • To ensure any absence from work is recorded correctly
  • To ensure you are able to use your full entitlement of annual leave
  • To ensure that any leave you are entitled to is administered correctly

We do this because we have a legitimate interest to maintain our employment records.

Examples

  • Details of any absence management processes you are involved with, including any meetings you are invited to
  • Details of any disciplinary proceedings you are involved with, including any meetings you are invited to
  • Details of any grievance proceedings you are involved with, including any meetings you are invited to and any statements you provide

Purpose

  • To ensure our internal processes are followed
  • To ensure you are fully supported through any proceedings
  • To monitor your progress against any agreed actions

We do this in order to perform our contract with you.

Examples

  • Records of any quality checks carried out on your work, including call recordings
  • Records of your monthly 121 meetings with your manager
  • Any Performance Development Plans (PDPs) which you have in place
  • Any Performance Improvement Plans (PIPs) which you have in place
  • Details of any performance management proceedings you are involved with, including any meetings you are invited to

Purpose

  • To ensure our internal processes are followed
  • To ensure you are fully supported through any proceedings
  • To help you improve and develop your performance
  • To monitor your progress against agreed development goals
  • To monitor your performance against team and individual targets

We do this in order to perform our contract with you.

Examples

  • Your salary and bank details
  • Your pension
  • Any employee benefits you are entitled to (for example: cycle to work schemes and annual leave purchase)
  • Your nominated beneficiaries

Purpose

  • To ensure your salary is paid correctly
  • To maintain your pension and make agreed contributions
  • To ensure any employment benefits are provided correctly
  • Where necessary, to ensure any nominated beneficiaries are paid

We do this in order to comply with the law.

Examples

  • Details of any Display Screen Equipment (DSE) assessments you have completed
  • Details of any reasonable adjustments put in place to allow you to carry out your role
  • Details of any reasonable adjustments put in place to allow you to carry out your role
  • Details of any Occupational Health referrals, and records of any advice given

Purpose

  • To ensure your salary is paid correctly
  • To ensure any issues identified are resolved
  • To ensure that we are providing any adjustments necessary
  • To ensure we have a record of advice provided by Occupational Health to support you

We do this in order to comply with the law.


Employment Functions

Examples

  • Records of any Health & Safety training you've received
  • Details of any voluntary positions you hold (such as Fire Marshal or First Aider)
  • Your colleague ID card, including your name and face

Purpose

  • To ensure you receive all relevant training
  • To protect the safety of our colleagues
  • To protect the security of our offices and equipment

We do this in order to comply with the law.

Examples

  • Your IP address
  • Details of any software you have downloaded onto a work device, and any licences you hold for software
  • Records of any tickets you raise with our IT service desk

Purpose

  • To ensure the safety of our IT network and equipment
  • To protect the charity against malicious software and phishing attacks
  • To monitor any issues with our systems and equipment

We do this because we have a legitimate interest to protect our network and systems.

Examples

  • Records of any annual leave or other planned absence you have
  • Details of your career development goals and aspirations
  • Records of any developmental training you've received
  • Records of any mentorship programme you're involved with

Purpose

  • So we can plan to ensure a good level of service is provided to our clients
  • So we can support you in your development
  • So we can create succession plans

We do this because we have a legitimate interest to provide our service to our clients, and to develop our colleagues.

Examples

  • Records of any training you're required to complete by law
  • Regulatory references, where these are required for your job role
  • Details of any regulatory roles or responsibilities you hold

Purpose

  • So we can maintain our regulatory records
  • So we can demonstrate that we're complying with regulatory requirements

We do this because we have a legitimate interest to demonstrate that we're complying with our regulators.

Examples

  • Records of any gifts or hospitality that you receive from clients or partner organisations

Purpose

  • So we can maintain our regulatory records
  • So we can ensure that our internal gifts and hospitality processes are followed
  • To avoid any potential conflicts of interest

We do this because we have a legitimate interest to demonstrate that we're complying with our regulators.


Colleague Engagement

Examples

  • Anything you post on our internal social media
  • Information that colleagues have shared about you
  • Your basic personal identifiers

Purpose

  • So we can provide an internal social media for our colleagues
  • So we can consider nominations for internal awards, including our Iain Kendall award
  • So we can send you a card on your birthday

We do this because we have a legitimate interest to promote and support the engagement of our colleagues.

Examples

  • Anything you share on our annual Colleague Engagement Survey
  • Anything you share on any “temperature check” surveys we carry out
  • Any feedback or questions you share with your Joint Consultative Committee (JCC) representative

Purpose

  • So we can regularly monitor how our colleagues feel about their work, and about StepChange as an employer
  • So we identify any issues affecting our colleagues
  • So your JCC representative can share any concerns or questions you have

We do this because we have a legitimate interest to promote and support the engagement of our colleagues.


Day to Day Activities

Examples

  • Details of your working pattern, daily schedule and responsibilities
  • Records of any short-term absence (for example, GP or hospital appointments)
  • Records of conversations with your manager about performance, absence or personal issues

Purpose

  • So we can plan work around the availability of our colleagues
  • So we can ensure work is covered in your absence
  • So we can help support you through any performance, absences or personal issues
  • So managers can handle the day to day running of their teams

We do this because we have a legitimate interest to provide our services to clients. In some cases, we will also do this in order to perform our contract with you.

Examples

  • Records of internal correspondence from, to or concerning you
  • Copies of any reports concerning you (for example, departmental performance reports)
  • Records any Microsoft Teams messages from, to or concerning you

Purpose

  • So our colleagues can correspond with each other
  • So colleagues can share important work information

We do this because we have a legitimate interest to provide our services to clients. In some cases, we will also do this in order to perform our contract with you.

Examples

  • Recordings of telephone conversations between you and clients
  • Records of other interactions you have had with clients (such as emails or webchats)
  • Records of any notes you make on our systems concerning clients

Purpose

  • To handle complaints
  • To look into conduct issues
  • To check the quality of our services.

We do the above to meet financial regulations and rules.

  • Listening to calls for training
  • We may let third parties listen to live calls. These could be journalists or funders. This is to promote our services and raise awareness of our charitable aims
  • To provide evidence for any law enforcement investigations
  • To protect your wellbeing by investigating any abusive behaviour by callers
  • To monitor the quality of our services.

Clear and strict rules are followed at all times to protect your information.

We do this because we have legitimate interests to promote our services, train our colleagues, report criminal activity and look after our colleagues.


Miscellaneous

StepChange carry out events & publicity activities, and sometimes we ask colleagues if they would like to participate in these. If you wish to participate in any of these events, we recommend you read our Events & Publicity Privacy Notice.

Examples

Where you make a qualifying disclosure concerning any of the following areas, and you choose not to remain anonymous:

  • A criminal offence
  • A miscarriage of justice
  • An act creating risk to health and safety
  • An act causing damage to the environment
  • A breach of any other legal or regulatory obligation
  • Breaches of internal policies and procedures
  • Bullying, harassment or discrimination
  • Inappropriate conduct or unethical behaviour
  • Financial irregularities or fraud
  • Bribery or corruption
  • Negligence
  • Concealment of any of the above

Purpose

  • To allow us to investigate any concerns you have raised
  • To support you through this process
  • To feed back to you where possible
  • To ensure you suffer no detriment or disadvantage as a result of making a disclosure

We process this data where we need to so we can:

  • Comply with the law
  • Prevent or detect unlawful acts
  • Prevent fraud

Examples

  • Recordings of any safeguarding disclosures or concerns you raise, about colleagues or clients

Purpose

  • So we can ensure any safeguarding issues we become aware of are handled appropriately

We do this in order to comply with the law, and because we have a legitimate interest to safeguard our clients and colleagues.

Examples

  • Any information about EDI that you choose to share with us (for example, details of sexuality, neurodiversity or ethnicity)

Purpose

  • So we can understand the demographic makeup of our colleagues and uphold our commitment to a diverse workforce

We will process this data when we have your consent to do so.

Examples

  • Arranging a courier

Purpose

  • If we need to securely deliver work equipment or collect it from you.

We will process this data only when we have a lawful basis for doing so. This will depend on the nature of the processing activity.

Where you have chosen to share this with us - for example, where you have been the victim of a crime that affects you at work.

Examples

Relevant details of:

  • Criminal activity
  • Criminal allegations
  • Criminal investigations
  • Criminal proceedings
  • Criminal offences (and absence of offences)
  • Criminal penalties
  • Criminal convictions

Purpose

  • To make sure we can offer you any support that you need

We process this type of sensitive data where we need to.

There may be times when we need to ask you if you agree to the use of specific sensitive personal data for these or other purposes.

Examples

  • Information shared as part of legal proceedings involving us and you
  • This could be sensitive information. It may relate to you and your situation

Purpose

  • Establishing, exercising or defending legal proceedings
  • Where we are subject to a court order

Examples

Information about any complaint, rights request, or other legal request which you may have submitted.

This can include:

  • Details of the request
  • Our investigations, and
  • How we have responded

Information about you where this is required to investigate any issues that we have discovered. Such as if your data is involved in a data breach.

This could be:

  • Sensitive information
  • Related to you and your situation

Purpose

  • To maintain records as required by law or because our regulators tell us to do so
  • Where we have a legitimate interest to maintain records about our compliance with the law
  • To fully investigate any complaints or answer any information request you may have.

This notice does not form part of any contract with you. We may update this notice at any time.

Published: January 2026. (Version 3).