T.J.LOWERY (SUB-CONTRACTORS)Ltd is committed to protecting the privacy and security of your personal information. As a data controller it is our responsibility for deciding what information we hold about you and how it is stored.

This Privacy Policy tells you how we collect your information, what information we collect, why we collect it, how long it’s kept for, where it is stored, how it is protected, your rights in relation to your personal information and how you can contact us in the event that you have a complaint.

Contact Details:

Address: T.J.LOWERY (SUB-CONTRACTORS)Ltd, Riverside View,
Old Basing Basingstoke, Hampshire     RG24 7AL.

Phone number: 01256 465601.

e-mail: admin@tjlsub-contractors.co.uk

Representative and Data Protection Officer: T.B.A.


In collecting and processing your personal information, we will comply with the data protection law in place at the time. This requires that the personal information we hold about you must 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 informed you about and limited to those purpose only.
  • Accurate and kept up to date.
  • Kept only as long as is necessary for the purposes we have told you about.
  • Kept securely.


If when required you fail to provide us with personal details this could mean we are unable to fulfil our obligations such as those set out in an Employees Contract of Employment (E.g. paying you or providing you with Statuary Sick Pay if a Doctors Certificate is not presented when asked for.) or comply with our legal obligations. (E.g. Those under the H.S.E, Inland Revenue etc.)


T.J.LOWERY (SUB-CONTRACTORS)Ltd will only Process and store your information for the purposes that have been outlined in this policy. If we need to use your information for an unrelated purpose we will inform you and provide you with the LEGAL BASIS for doing so.

Do we need consent to process and store your information:

T.J.LOWERY (SUB-CONTRACTORS)Ltd does not need your consent if we use your personal information in accordance with this written policy, to perform our legal obligations or to exercise specific rights in the field of Employment Law.

Under rare circumstances we may ask for your written consent to process particularly sensitive data. In this instance we will provide full details of the information we would like to process explaining why we need it in order for you to carefully consider whether you wish to consent. You should be aware that there is no condition in your contract that implies you should agree to any request for consent from us.

How we collect your information:

  • Filling in of Starter forms upon job offer.
  • Weekly records of attendance acquired once a week.
  • Any information relating to time of work such as illness and holiday records and maternity leave.
  • When any information is submitted by a Contractor or Consultant for the purposes of verification.

Information we collect:

We collect one or all of the following pieces information which you provide us with through the means listed above.

  • Name
  • Date of birth
  • Telephone Number(s)
  • E-mail address
  • Address
  • National Insurance Number
  • Bank Details
  • Original Contracts of Employment
  • U.T.R Numbers
  • Passport (Copy)
  • Driving licence (Copy)
  • C.S.C.S Cards (Copies)
  • Relevant qualifications
  • Attendance Record/Holiday Records
  • Maternity leave records
  • Relevant Insurances
  • Doctors Certificates
  • Any information relating to disciplinary procedures
  • Accident reports
  • C.C.T.V recordings

How we collect your information:

Below we have explained why we collect and process your information, who it is disclosed to and our basis for doing so.

Contact, bank and other personal details (Numbers 1-13 under Section ‘Information we collect’.) – With the exception of telephone numbers and e-mail addresses which may be passed onto third parties, your bank and other personal details will only be disclosed to members of the organisation at Head Office who are responsible for supervision or the provision of payroll functions, pension providers, legal or HR providers. Phone numbers and e-mail addresses may be passed onto delivery drivers for fixings, tool suppliers, hirers, building supply merchants Clients or Clients representatives or to any institution where we require security clearance such as ports, airports, military etc.

Your phone numbers and e-mail addresses may be disclosed to delivery drivers to ensure fixings, building materials, tools etc make it to site , get delivered to us on site directly and overall to benefit the progress and efficiency of our contracts. 

All other contact/bank and personal details are processed in order for verification purposes, to ensure correct legal information under Contract of Employment and legislative bodies such as HMRC and to enable payment of weekly wages, monthly salary, National Insurance, expenses and pension contributions.

The LEGAL BASIS for processing this information is that it is necessary for the performance of the contract that the data subject is party.

Attendance records and holiday records- (Numbers 13-14 under section ‘Information we collect’.) This information is disclosed by members of the organisation who supervise and /or may be involved in performance monitoring, payroll, legal and HR advisors. This information is processed to ensure appropriate levels of conduct and performance are being met and maintained, to highlight any inconsistencies in conduct and performance and allow us to take appropriate action, raise concerns about an Employee’s health and to maintain staffing levels in the event of an Employee’s or Self- Employed members absence.

The LEGAL BASIS for processing this information is that it is necessary for the performance that the data subject is party to and necessary for the legitimate interest of running our organisation competitively and efficiently and for compliances with our legal obligations.

Relevant insurances- When we require the services of an outside contractor or independent consultant we may request up to date copies of Professional, Public and or Employers Liability Insurance Certificates. Such information will only ever be disclosed to office personal and our Insurance providers.

Doctors certificates- Copies of Doctors Certificates are for office personal use only and are used to claim SSP. This information is processed in order to confirm am Employee’s eligibility for Statutory Sick Pay.

The LEGAL BASIS for processing this information is that we as an organisation are entitled to request this under the Statutory Sick Pay Act 1982 should the Employee be off work due to illness for seven consecutive days before we process SSP.

Disciplinary and grievance records – This information is only disclosed to office personal who may be involved in investigating and/or determining disciplinary, grievance or legal procedure.

The LEGAL BASIS for processing this information is that it is necessary for the performance of the contract to which the data subject is party and necessary for the legitimate interests of funning the organisation competitively and efficiently.

Accident reports-This information is disclosed to office personal and to HSE. Such information has to be processed in order to enable the Health & Safety officer to investigate an accident and may also aid the data subject in the potential pursuit of a claim.

The LEGAL BASIS reason for processing this information is that it is required to fulfil our legal obligations under the RIDDOR Act 2013.

C.C.T.V Monitoring: This applies to our offices at Riverside View only. The LEGITIMATE BASIS for implementing this system is that it is vital for controlling the perimeter and buildings for security purposes, deterring criminal activities such as burglaries and insurance purposes. 

Criminal offence data: We currently do not process criminal offence information.

Data Security:

Below we have explained why we collect and process your information, who it is disclosed to and our basis for doing so.

T.J.LOWERY (SUB-CONTRACTORS)Ltd has taken appropriate security measures to ensure that your personal data is not lost, stolen, misused, accidently destroyed, altered, or disclosed to anyone other than our employees for the sole purpose of performing their work related duties.

We have anti-virus and malware in place as well as a firewall to prevent unwanted access and our software is updated daily. Any hard copies of your personal information are kept within a lockable filing cabinet which is only accessible to two members of office staff who require access in order to carry out duties in relation to payroll and/or supervision etc.   

We limit the access of your data to third parties who have a business need to know. These third parties are operate under a duty of confidentiality and our bound to implement appropriate technical and organisational measures to ensure the security of data regulations these organisations are also duty bound to provide appropriate security measures for your data.

We have put in place procedures to deal with any suspected security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Your duty to inform us of changes:

It is important that any personal data we hold is both 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 data:

Under certain circumstances the law grants you specific rights. (See below.) Please note that such rights may be limited in certain situations, for instance if they prevent us from fulfilling our legal obligations;

  • Request access: You may submit a data subject access request by contacting Head Office. This will enable you to receive a copy of all the information we hold on you and check that we are lawfully processing it. You may be able to make a request for access through a third party E.g a solicitor, however we must be satisfied that the third party are acting on your behalf and will ask for confirmation. If a request for access is made a copy of all information we hold on you will be made available in electronic format unless you request otherwise.
  • Request data correction: This enables you to have any incomplete or inaccurate information we hold on you corrected.
  • Request erasure (Right to be forgotten.): You may request for any information we hold on you to be erased but only where there is no good reason to process it. You may object in this way if;
  1. If you believe the personal data we hold on you is no longer necessary for the purpose  which we originally collected or processed it for.
  2. We rely on your consent as a lawful basis to  hold your  information  and  you  withdraw  your consent.
  3. You believe there is no legitimate basis for us to continue processing any of your information.
  4. You believe we are processing your information for the purposes of direct marketing and you object to that processing.
  5. You believe we have processed the information unlawfully.
  • Object to processing your information: You may object to the processing of your information if you feel that:
  1. Your information is being processed unlawfully.
  2. You have an issue with its accuracy.
  3. If we no longer need your information but you require us to keep it in order for you to establish, exercise or defend a legal claim
  • Restrict the processing of your data: You may ask us to suspend the processing of your information, for example if you want to establish its accuracy or the reason for us processing it.
  • Request transfer: You may if you wish request that we transfer your information to another party.

If any of the above requests are submitted to Head Office T.J.LOWERY (SUB-CONTRACTORS)Ltd will not charge a reasonable fee unless your request for access is unfounded or excessive. Under such circumstances we may refuse to comply. Any request can be either verbal or in writing initially and in both cases will be recorded electronically on file. You will then be sent a ‘Subject request form’ which will enable us to establish the information you require. We will respond to all requests within one month of receipt of the request.

If a request for access is made T.J.LOWERY (SUB-CONTRACTORS)Ltd may ask for specific additional information as an extra security measure to ensure your details are not being disclosed to any party who has no right to access them.

Automated decision making and profiling:

T.J.LOWERY (SUB-CONTRACTORS)Ltd does not make automatic decisions or undertake in automated decisions regarding individuals to evaluate certain information about that individual. (profiling.)

Right to withdraw consent:

In any circumstances where you have submitted a request you may at any time withdraw your consent by contacting Head Office.

Right to complain:

If you have a concern regarding the information we hold about you, please contact our Data Privacy Manager (TBA) either by e-mail, adimin@tjlsubcontractors.co.uk or by phone 01256 465601 where we will endeavour to resolve any issues or complaints raised.

If you are in anyway dissatisfied with our approach to your complaint you may wish to contact the Information Commissioner’s Office at https://ico.org.uk/concerns who are the UK’s supervisory authority under The General Data Protection Regulation.