Version 1 — draft for review. This policy explains what personal information we hold about you in TMP, our workforce and job management system, why we hold it, who we share it with and what your rights are. It applies to operatives (whether employed, subcontracted or supplied through another company), office staff and customer users of TMP, on the website, the TMP mobile app and the customer portal.

1. Who we are

Elite Traffic Management ("we", "us", "our") is the data controller for the personal information in TMP. We are registered in England and Wales (company number [Company number]) and our registered office is at 8 Brunell Gate, Brunell Industrial Park, Harworth, Doncaster, DN11 8QB, United Kingdom. We are registered with the Information Commissioner's Office (ICO) under registration number [ICO registration number].

For any privacy question or to use your rights, contact our [Data protection contact] at [Data protection email] or [Contact phone], or write to us at 8 Brunell Gate, Brunell Industrial Park, Harworth, Doncaster, DN11 8QB, United Kingdom.

2. The information we hold

About you and how to contact you

• Your name, username, email address, phone number, home address and date of birth.
• Your next of kin's name, relationship, phone number and address, to use in an emergency.

Your eligibility to work

• Your right-to-work basis, copies of your right-to-work documents and their expiry dates, and your National Insurance number.
• Your qualifications, cards and licences (for example Lantra, Streetworks and Highways cards, and your driving licence number, type and expiry), with photos of them and your insurance documents.

Health and safety information (special category data)

• Medical and fitness-to-work certificates and their expiry dates.
• Drug and alcohol test results.
• Details of injuries and health in accident and incident reports.
• Sickness absence and the reasons you give for it.

Your work with us

• The jobs and shifts you are booked on, your shift status updates, timesheets, pay rates, pay and deductions. If you are employed by us, your contract details, salary and contracted hours.
• Forms, vehicle checks, defect and incident reports you complete, and the photos you take for them.
• Health, safety and quality documents you have signed, inductions, training and quiz results.
• Feedback from customers, and records of issues, investigations and restrictions on where you can work.
• Penalty notices and fines connected with vehicles you were driving.

Location

• Photos taken in TMP record the time and your phone's location when the photo was taken, so that we and our customers can confirm that work was done when and where it should have been.
• Some forms ask you to record a location.
• Company vehicles may be fitted with telematics equipment that records where and how the vehicle is driven.
• TMP does not track your location at any other time.

Customer users

• Your name, email address, company, depot and role, and the job requests, feedback and approvals you make.

Technical information

• Records of when you sign in and out, your IP address and your browser or device. If you use the mobile app, we also hold a token that lets us send it notifications.
• A record of changes made to accounts and settings, and who made them.

3. Where the information comes from

Most of it comes from you, when you register, update your profile or use TMP for your work. Some comes from our office staff (for example bookings, pay and approvals), from our customers (for example feedback about your work), from test or occupational health providers, and from public sources such as the DVLA vehicle register.

4. Why we use it, and our legal reasons

Data protection law requires us to have a lawful reason for each use of your information. We use it:

• to manage your work with us: booking you onto jobs, sending you job details, recording your work, and paying you. This is necessary for the contract we have with you, or for the contract with the company you work through;
• to meet our legal obligations: checking your right to work in the UK, keeping tax and payroll records, keeping you and others safe at work, recording and reporting accidents, and making sure only qualified and licensed people carry out work that requires it;
• for our legitimate interests: running and planning our operations efficiently, proving to customers that work was carried out properly, managing our vehicles, dealing with complaints and disputes, and keeping TMP secure. We have balanced these interests against your rights. You can object (see section 10);
• with your consent, where we ask for it. You can withdraw consent at any time.

We use health information (medical certificates, drug and alcohol test results, injuries and sickness) only where necessary:

• to meet our employment, health and safety and social protection obligations;
• to assess your fitness to work;
• to establish, exercise or defend legal claims.

Access to it is restricted to the staff who need it.

5. Automatic checks and our AI assistant

TMP checks your right-to-work, medical and qualification records before you can be booked onto a job. It will not let you be booked if a required document is missing or has expired. These are fixed rules, not judgements about you. A member of our staff reviews your documents, and you can always ask us to look again or update your records.

Our office staff may use an AI assistant inside TMP to help find suitable people, plan bookings and answer questions. To do this, it may process operatives' names, contact details, location (town or postcode), qualifications, availability and work details. The assistant cannot make changes on its own: every change it suggests must be approved by a member of staff. It is provided by [AI service provider], which processes the information on our behalf under a contract.

6. Who we share it with

• Our customers. When you work on a customer's job, we share what they need to confirm that you are eligible, qualified and fit to work on their site, and to manage the job. This can include your name, contact details, qualifications and cards, date of birth, address, next of kin details, and copies of your right-to-work, medical and licence documents. Customers can see this only for operatives who have worked on their jobs. They also see job records, photos and reports from those jobs.
• Payroll and pay. Umbrella companies, payroll providers and accountants who process your pay, and HMRC.
• Service providers who run TMP for us, under contracts that require them to protect your information and use it only on our instructions:
  • our hosting provider, [hosting provider];
  • our email delivery service, [email provider];
  • the mobile app notification service (Expo);
  • our AI assistant provider, [AI service provider];
  • our vehicle telematics provider, [telematics provider];
  • drug and alcohol testing and occupational health providers, [providers].
• Others, where needed: our insurers, professional advisers and auditors, and authorities such as the Home Office, HMRC, the Health and Safety Executive or the police, where the law requires or allows it. If our business is sold or merged, we may also share it with the new owner.

We never sell your personal information.

7. Information sent outside the UK

TMP is hosted in [the United Kingdom]. Some of our service providers (for example the email, notification and AI services) may process information outside the UK. Where they do, we make sure there is legal protection in place, either a UK adequacy decision or the UK International Data Transfer Agreement (or addendum).

8. How we keep it safe

TMP is only available over a secure (HTTPS) connection. Sensitive personal details and uploaded documents are encrypted when stored. Access is limited by role, so people see only what their job requires. Sign-ins are protected by limits on failed attempts and can require a code sent by email. Changes to accounts and settings are logged.

9. How long we keep it

Because our records support legal, financial, contractual and health and safety obligations, we do not delete accounts. When you stop working with us, your account is disabled and you can no longer sign in. We keep information only for as long as we need it, and then anonymise or remove personal details that are no longer needed. As a guide:

• right-to-work records: while you work with us and for 2 years afterwards;
• pay, tax and financial records: at least 6 years after the end of the financial year they relate to;
• accident, incident and health and safety records: at least [3] years, and longer where a claim is possible or the law requires it;
• medical and drug and alcohol test records: [period];
• job, booking and work records: [period], as our customers' contracts and possible claims require;
• sign-in records: 90 days. The record of account and settings changes: 30 days.

10. Your rights

You have the right to:

• ask for a copy of the personal information we hold about you;
• ask us to correct information that is wrong or incomplete (you can update much of it yourself in TMP);
• ask us to delete information. We will do so where we no longer have a legal reason to keep it;
• ask us to limit how we use your information, or object to us using it for our legitimate interests;
• ask for information you gave us in a format you can take elsewhere;
• withdraw consent where we rely on it.

To use any of these rights, contact us using the details in section 1. We will reply within one month. There is normally no charge.

If you are unhappy with how we have handled your information, please tell us first. You also have the right to complain to the Information Commissioner's Office: ico.org.uk, 0303 123 1113.

11. Cookies and storage on your device

TMP uses only the cookies it needs to work: a cookie that keeps you signed in, and security cookies, for example one that remembers a trusted device so you are not asked for a sign-in code every time. Your browser also remembers display choices such as light or dark mode. We do not use advertising or tracking cookies. The mobile app stores your sign-in securely on your phone and keeps a copy of your upcoming work so that you can use it without signal.

12. Changes to this policy

We may update this policy. When we make a significant change, TMP will show you the new version and ask you to accept it before you carry on.