Prospective Employee Privacy Policy

Welcome to the Babylon Employee Privacy Notice. We are committed to being transparent and complying with our legal obligations. We want you to know why we may collect certain information and what we do with it.

The policy will outline:

1. Who we are
2. What information we collect about you and how we do it
3. How and why we process your personal data
4. How and why we share your personal data
5. How we protect your personal data
6. How long we keep your personal data
7. Your rights

• Our employees, prospective employees and contractors are engaged by one of two companies within our group, which are both registered in England and Wales: Babylon Healthcare Services Limited and Babylon Partners Limited (together “Babylon”). The registered office and principal place of business for both companies is Babylon, 1 Knightsbridge Green, London, SW1X 7QA (the “Office”).
• Clinical employees are mostly employed by Babylon Healthcare Services Limited and non-clinical employees are mostly employed by Babylon Partners Limited. When exercising your rights under data protection laws, both companies act as one.
• This privacy notice applies to Babylon’s UK office and currently includes Babylon, 1 Knightsbridge Green, London, SW1X 7QA. The office location may change from time to time.
• When this notice refers to “Babylon”, “us” or “we”, it is a reference to your specific employer or prospective employer.
• Under the UK Data Protection Act 2018, Babylon shall be the ‘data controller’ of your personal data. We’re responsible for how your personal data is handled and what it’s used for through your employment with Babylon.

We collect and process a range of information about you through your application forms, cover letters, CVs or resumes, from correspondence with you, interviews, meetings, other assessments and through your employment relationship with us. In some instances, Babylon will collect information about you from third parties, such as references supplied by former employers.

Babylon may collect and process a range of information about you, which includes but is not limited to the following:

• your name, address and contact details, including email address and telephone number, date of birth and gender;
• details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers;
• details of your correspondence with us;
• information about your remuneration, including entitlement to benefits such as pensions or insurance cover;
• information about your marital status, next of kin, dependants and emergency contacts;
• information about your nationality and entitlement to work in the UK;
• information about your criminal record;
• details of your schedule (days of work and working hours) and attendance at work;
• details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;
• assessments of your performance, including appraisals, performance reviews and ratings, training you have participated in, performance improvement plans and related correspondence;
• information about medical or health conditions, including whether or not you have a disability for which Babylon needs to make reasonable adjustments;
• details of trade union membership;
• equal opportunities monitoring information which you may volunteer, including information about your ethnic origin, sexual orientation, health and religion or belief;
• use of computer software, applications, workspace messaging tools, email and the internet; and
• when attending our Office, we may collect static or moving imagery via CCTV or surveillance systems. Babylon collects imagery via CCTV cameras and surveillance devices located throughout the Office. CCTV notices are located in our Office.

3.1 Employment relationship

We need to process your personal data, in order to start the recruitment process once you apply for an available position, progress it and, if successful, to meet our obligations under your employment contract. Certain information, such as contact details, your right to work in the UK and payment details, employment references have to be provided in order to enable Babylon to potentially enter a contract of employment with you. If you do not provide certain required information, this may hinder Babylon's ability to administer the rights and obligations arising as a result of the employment relationship efficiently.

Babylon has a legitimate interest in processing personal data before, during and after the end of an employment relationship. Processing your personal data allows Babylon to do the following activities, which include but are not limited to:

• running recruitment and promotion processes;
• maintaining accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights;
• obtaining occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled;
• ensure effective general HR and business administration;
• respond to and defend against legal claims;
• maintain and promote equality in the workplace;
• ensure use of Babylon’s devices (including laptops) adhere to staff handbook guidelines and/or policies (including Babylon’s Acceptable Use Policy which for example, clarifies restrictions relating to personal email or internet use),
• application control of devices, in order to provide updates and allow for deployments of future business enterprise applications, remote access to wipe compromised devices; and
• maintain the safety and security of the Office for our colleagues, visitors and stakeholders, including but not limited to detection and prevention of crime; monitoring flows and demand throughout the Office to optimise resourcing; support the effective management of the Office operation and any incidents; for investigative purposes or as evidence to support follow-ups into Office incidents; and in response to a subject access request.

Where we rely on legitimate interests as our reasons for processing your personal data, we have applied a balancing test, where we have considered whether or not our legitimate interests are overridden by the rights and freedoms of applicants, employees or workers, and we have concluded that they are not. We will make sure that our interests never come before your rights.

3.2 Employment law obligations

Babylon will process personal data to enter into an employment contract with you and, if successful, to meet its obligations under your employment contract. We will also need to process your personal data to ensure that we are complying with our legal obligations, which include, but are not limited to, the following:

• checking you entitlement to work for Babylon (for example, your entitlement to working the UK);
• applying the appropriate tax rate;
• complying with health and safety laws;
• enabling employees to take periods of leave, to which they are entitled;
• checking trade union membership, in order for us to operate check-off for union subscriptions; and
• carrying out criminal records checks to ensure that individuals are permitted to undertake the role in question (for certain positions, such as clinical roles, for which it is necessary).

Some special categories of personal data, such as information about health or medical conditions, are processed to comply with legal obligations, such as those in relation to employees with disabilities. Where Babylon processes other special categories of personal data with your consent, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring.

3.3 Automated decision-making

Employment decisions are not based solely on automated decision-making.

Your information will be shared internally, including with members of the HR and recruitment team (including payroll), interviewers, the hiring manager, managers in the business area for the role advertised, and IT staff if access to the data is necessary for performance of their roles and respective Babylon functions.

Babylon shares your data with third parties, in order to obtain pre-employment references from other employers, obtain employment background checks from third-party providers and obtain necessary criminal records checks from the Disclosure and Barring Service.

Babylon may also share your data with third parties if it has a legal obligation to do so (for example in response to requests from law enforcement agencies or court orders).

Babylon may also share your data with third parties in the context of a sale of some or all of its business In some circumstances, Babylon may share information with certain third parties, for example, when required by law or court order, or as requested by any government or regulator or law enforcement authority or agency. Full consideration will be given to the applicable data protection legislation when making decisions about whether such records should be shared.

Babylon may also share your data with third parties that process data on its behalf, in connection with payroll, the provision of benefits and the provision of occupational health services. For these purposes, your data may be transferred to countries outside the European Economic Area (EEA). Where we may transfer your data to companies outside the EEA, we will protect it in a manner that is consistent with our legal obligations. This can be done in a number of different ways, for instance:

• the country that we send the data to might be approved by the European Commission (including, post-Brexit); or
• the recipient company might have signed up to a contract obliging them to protect your information.

We might also process your health data to protect public health. Your data could be vital to help research, monitor, track and manage public health emergencies, like pandemics. In a public health emergency, your information may be shared only in a way that is appropriate and lawful (for example, with your consent, or if there is a health emergency or an overriding public interest) with organisations such as: NHS Digital, NHS England and Improvement, Public Health England, Local authorities, Health organisations, and GPs. We will limit the use or sharing of data to the period of the emergency/ pandemic and will only share minimal data to the extent necessary. Wherever possible, we would seek to anonymize the data, so that we minimize processing of personal data that is subject to data protection laws and you therefore cannot be identified.

Babylon takes the security of your data seriously. Babylon has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except when necessary by its employees in the performance of their duties.

Where Babylon engages third parties to process personal data on its behalf, they do so on the basis of written instructions. Such third parties are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of personal data.

Babylon will hold your personal data relating to your application to work at Babylon, for two years from the date of your application submission. We do so in order to be able to contact you for any further job opportunities, in the event your application is unsuccessful. You can opt out of the two year retention period at any time by emailing us at people@babylonhealth.com.

In the event your application is successful, Babylon will hold your data in line with our current Records Retention and Disposal Policy, and as amended from time to time. Please check these policies on Bamboo.

You’re in control of your personal data. Under the UK Data Protection Act 2018, you have the right to:

• access and obtain a copy of your data on request;
• require Babylon to change incorrect or incomplete data;
• require Babylon to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
• ask for your data to be provided in a portable format that allows you to move, copy or transfer it. Or ask us to send it in this format to someone else;
• object to the processing of your data where Babylon is relying on its legitimate interests as the legal ground for processing; and
• ask Babylon to stop processing data if it is inaccurate or there is a dispute about whether or not your interests override Babylon's legitimate grounds for processing data.

To do any of these things, please contact us at: Data Protection Officer, Babylon, 1 Knightsbridge Green, London, SW1X 7QA. Alternatively, contact by email at: DPO@babylonhealth.com.

We’re regulated by the Information Commissioner’s Office (ICO). If you’re not happy with any aspect of our data handling, you can complain to the ICO directly. You can contact them at:Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire,SK9 5AF, Phone: 0303 123 1113.