Staff and Supplier Privacy Notice (GDPR/DPA Supplement)
Owner: Privacy Department
Approver: Global Privacy Officer
Version: December 2021
Last Reviewed: December 2021
- Who does this Notice apply to?
- Who controls your personal information?
- Why do we collect your personal information?
- When do we collect your personal information?
- What personal information do we collect and process?
- Who do we share your personal information with?
- Where do we process and store your personal information?
- How long do we keep your personal information?
- What rights do you have over your personal information?
- How do we protect your personal information?
- Will this Notice change?
- Any questions?
- COVID-19 Pandemic
This Notice applies to prospective, current and former staff members and suppliers (including employees, apprentices, agency workers and contractors).
This Notice covers our staff and suppliers globally. You can click on the links below for additional terms that apply to staff and suppliers working in certain regions. The region-specific terms only apply to staff and suppliers that work in those geographic locations or as applicable law requires.
For simplicity throughout this Notice, ‘we’, ‘us’, ‘our’ and ‘Bright Horizons’ means the relevant related company of Bright Horizons; ’staff’ or ’staff member’ includes employee, apprentice, or agency worker; ’supplier’ includes contractor; and ’you’ or ’your’ means staff, staff member or supplier.
A separate Global Consumer Privacy Notice applies to prospective, current and former consumers using our services, websites, apps and social media.
Bright Horizons is made up of a number of related companies. This section gives you the legal name of the Bright Horizons company responsible for processing your personal information.
Bright Horizons has a Global Privacy Officer (who also acts as its Information Protection Officer for the UK and the Netherlands) and can be contacted at firstname.lastname@example.org.
Location of Employee/Supplier
United States, Canada, India
Bright Horizons Family Solutions LLC
200 Talcott Avenue South, Watertown, Massachusetts, 02472, USA. This entity also includes services under our brand names Bright Horizons, Bright Horizons EdAssist Solutions and College Coach.
United Kingdom, Ireland
Bright Horizons Family Solutions Limited (Co. No. 2328679)
2 Crown Court, Rushden, Northamptonshire, NN10 6BS, UK. This entity also includes services under our brand names Bright Horizons, Yellow Dot Nurseries, Asquith Nurseries, Magic Nurseries and My Family Care (MFC).
Kindergarden Nederland B.V. (Co. No. 33303797)
Herengracht 244, 1016 BT Amsterdam, Netherlands.
We limit the collection of your personal information to what is necessary. We do not sell your personal information to any third parties. Below we have highlighted the main reasons for collection:
- Evaluate employment applications or supplier tenders/proposals.
- Administration of your employment and/or contract.
- Comply with our contractual obligations to you.
- Fulfil or meet the reason you provided the personal information to us.
- Respond adequately to your requests for information.
- Create, maintain, customize, and secure your account with us.
- Research and analyse employment/supplier information for training and quality purposes.
- Comply with laws, regulations, sector standards and our policies.
- Fulfil tax, reporting, and other financial requirements and obligations.
- Prevent or detect unlawful acts.
- Protect the security of our technology and our Protected Information (as defined in our Global Privacy and Information Security Policy)
- As described to you when collecting your personal information.
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all assets of Bright Horizons, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
Staff or suppliers in the United Kingdom, Ireland, the Netherlands and any other country in European Economic Area click here to read additional information that applies to you.
There are a variety of contexts under which we will collect your personal information.
When you visit our websites or use our applications (apps) or social media, we collect your personal information from:
- Monitoring your electronic visit and engagement with us.
- The information you provide to us (for instance, by completing one of our web forms).
Our website is not intended for use by children under 16 years of age nor do we knowingly collect personal information from children under 16 through our website. If you are under 16, please do not use or provide any information on our website.
When you apply for a role with Bright Horizons as a prospective staff member, we will collect your personal information when:
- You create or update an account on our job application system.
- Your recruitment agency shares your personal information with us.
- You provide personal information necessary for your job application.
- You contact us for information about the role or your job application.
- We obtain personal information about you from third parties to process your job application, such as references, qualifications and criminal background checks.
During your on-going relationship with Bright Horizons as a staff member, we will collect your personal information when:
- You use a Bright Horizons’ device we will monitor your digital activities on that device including web browsing/visits.
- We create your Bright Horizons’ employee account and you update your information.
- You or we complete electronic and paper forms, assessments and other documentation that processes your personal information.
- You download or install one of our apps that processes your personal information.
- We monitor your IT use on Bright Horizons’ digital devices, technology and systems.
- Where Bright Horizons uses your image (either as a photograph provided by you or taken by us), either internally or externally.
If you are a prospective staff member or supplier, we will process:
- All personal information that you provide to us.
- Information from third parties about your suitability for your role including, if applicable, disqualification from childcare roles, criminal background records, references and training/qualifications.
- For locations with CCTV cameras, images may be captured.
- Other information as necessary to process your application.
- Sensitive personal information which could include:
- information about your race or ethnicity; religious beliefs; sexual orientation (for equal opportunities monitoring purposes);
- information about your health as relevant to your role; and
- criminal background records as relevant to your role.
If you are a current or former staff member or supplier, we will process:
- All personal information that you provide to us.
- Details of your digital activities when using a Bright Horizons device.
- Employment or supplier records (e.g., compensation and benefits details, payroll records, tax status information, performance/disciplinary/grievance information, absences for sick and other types of leave, dates of employment, reason for leaving, location(s) of employment, training/qualifications and other general HR and business administrative records).
- Information obtained through electronic means such as digital devices, swipe card records and key fob access records.
- Photographs and biometric information (fingerprints).
- For locations with CCTV cameras, images may be captured.
- Records of employee and supplier contractual and statutory rights.
- References about you either given by us or obtained from third parties.
- Information that enables us to respond to and defend legal claims or to pursue legal claims.
- Personal information provided to us in order to meet our legal obligations.
- Sensitive personal information could include:
- information about your race or ethnicity; religious beliefs; sexual orientation, gender (for equal opportunities monitoring purposes);
- information about health or medical conditions to manage our employment law and health and safety obligations for sick leave/absences, disabilities, and suitability to perform your role;
- occupational health advice and other information about your health as relevant to your role; and
- criminal background record checks as relevant to your role.
Staff and suppliers who are residents of California click here to read additional information that applies to you.
Staff and suppliers located in the United Kingdom, Ireland, the Netherlands and any other country in the European Economic Area click here to read additional information that applies to you.
We consider your personal information confidential and do not share it with anyone else except as described in this Notice. There are limited circumstances that require us to disclose your personal information to others in order to meet our contractual or legal obligations or legitimate business interests. Examples include:
Bright Horizons’ Group Companies
- We may share your personal information with our subsidiaries and affiliate/group companies as necessary to administer your employment/contract.
Sub-contractors and Agents
- We sometimes employ or contract with other companies and individuals to perform functions on our behalf. Depending upon the type of service they are providing, we may share personal and special category (sensitive) information only as appropriate and necessary. These parties are under contractual obligations to use your personal information only as directed by us and as needed to perform their functions. All are under a legal duty to handle such information in accordance with information protection law, Bright Horizons’ information security and confidentiality standards, and this Notice. Some examples include our insurance brokers/provider, payment service providers, external legal/financial/tax advisors, and IT developers.
- We share personal information of our staff with benefit partners in order to provide benefits to you for which you are entitled. All are under a legal duty to handle such information in accordance with information protection law, Bright Horizons’ information security, privacy and confidentiality standards, and this Notice.
- If you are an employee, contractor or agency worker at one of our Corporate Client Nurseries or within Backup Care Services, we may share certain personal information with our corporate client as required by our contract with them. This will always be in accordance with applicable information protection laws and regulations.
Third Parties to Comply with Legal Requirements
- As we continue to develop our business, we might sell or buy assets. If any Bright Horizons business unit is sold, personal information relevant to the operation sold may be transferred as part of the transaction.
- Some personal information may remain on electronic storage data systems in the country where you work or provide services. However, our primary electronic storage facilities and contact centers are in the United States. Please note that we (or our Affiliates, service providers or agents) may process personal information in other countries, where your personal information may be subject to the laws of that jurisdiction, including laws regarding the disclosure of personal information to government authorities. We ensure appropriate safeguards are in place before we transfer personal information to any other country.
- Staff and suppliers working in the United Kingdom, Ireland, the Netherlands and any other country in the European Economic Area click here to learn more about how we safeguard your information and comply with privacy laws.
- The hardcopy of personal information we collect remains in the country where you work or provide the services.
Whenever we collect or process your personal information, we’ll only keep it for as long as is necessary for the purpose for which it was collected and as required under law. At the end of that retention period, your information will either be deleted completely or anonymized, for example by aggregation with other information so that it can be used in a non-identifiable way for statistical analysis and business planning.
To ask for your information to be amended, please follow one of the steps below:
- If you have an online account, update the information directly online.
- Contact your line manager to request the amendments.
- Contact the Human Resources Department to request the amendments.
If you have any questions about your privacy rights, you can contact our Global Privacy Officer at email@example.com.
Residents of California click here to read additional information that applies to you.
Staff and suppliers working in the United Kingdom, Ireland, the Netherlands and any other country in the European Economic Area click here to read additional information that applies to you.
We utilize appropriate technical, organizational, and physical safeguards to protect your personal information we process in both physical and electronic formats. We provide information protection, privacy and security training and conduct internal periodic quality assurance audits to ensure we maintain these standards.
However, please note that no computer system or information can ever be fully resilient against every possible hazard or risk. We do maintain appropriate levels of security in accordance with information protection, privacy and security laws and regulations in the territories we operate and keep these under review.
You also play a valuable part in protecting the security of your information. You should never share with anyone your password to access any accounts that you created or which we created for you (such as your employee account details). When using a browser to access your account, after you have finished you should log out and exit your browser to prevent unauthorized users from returning to your account.
If you believe that someone has improperly used your account or provided information about you that you did not authorize, please contact us immediately at firstname.lastname@example.org
This Notice is subject to change in order to remain compliant with data protection and privacy laws in the territories in which we operate. Please check back periodically, especially before you provide any personal information. This Notice was last updated in December 2021.
We hope this Notice has been helpful in setting out the way we process your personal information and how we do this in a transparent and accountable manner.
If you have any questions that haven’t been covered by this Notice, please contact our Global Privacy Officer at email@example.com.
In order to comply with our legal and regulatory obligations, we may need to collect personal information about you and individuals you have been in close contact with for COVID-19 related purposes. We may use this personal information to determine your access to a Bright Horizons premises. In addition, we may need to share this personal information with relevant government agencies. We will process and protect all personal information we collect for COVID-19 related purposes in accordance with this Notice.