Legal

Gender Pay Gap Report for Extrastaff Ltd for 2018

At Extrastaff we believe in diversity and inclusion at all levels and we are pleased to present our Gender Pay Gap Report for 2018. The specific figures are below, but to make sense of them we will need to explain more about our business.

We are a nationally known recruitment business, primarily based in the South East of England. We currently operate from 25 locations, with plans for further growth this year. The business was set up in 2003 with a focus on making Extrastaff the number one high street recruiter dealing with temporary driving and industrial personnel – essentially, specialising in the blue collar sector. After many awards both local, regional and national, and significant investment we are pleased to say that we are well on the road to achieving this.

Extrastaff now directly employ 100 valued colleagues throughout our business whose focus is on providing a high quality service to a wide range of clients from Large Blue Chip organisations through to Local Authorities. Our internal staff retention of over 80% is key to this being achieved and maintained.

In putting together this report, we have also included the many hundreds of agency workers that we engage, and who carry out duties for our clients up and down the country.

The driving sector makes up around 40% of our overall business. Drivers are paid a higher hourly rate for their work than their industrial counterparts due to the responsibilities that their job entails. In wider society the driving recruitment has reflected the types of career choices men and women have chosen to take. The historic dynamics of this sector means that over 90% of drivers are men, and whilst we have robust equal opportunities policies and procedures in place, which are regularly reviewed and rigorously enforced to ensure that there is no discrimination at work, the pool of available female LGV drivers remains very small. However, realistically and practically, we understand that it will take time to see concrete results here and that changes will not come overnight.

Direct employees of Extrastaff have exactly the same pay structure for people on the same level. In our branches, we have more women than men at manager level, and the majority of our employees are female. We currently have one female director, with three male directors. We have an equal split of men and women at senior management level. Extrastaff will always promote on merit, and we are currently focused in trying to ensure that there is true equality of opportunity for all employees at all levels.

Extrastaff is an energetic, forward thinking recruitment agency that takes pride in delivering the very best service that it can to its many clients around the country. We understand that having a contented, happy workforce is key to that. Extrastaff takes its commitment to equality of opportunity for women and men very seriously and this Report is only one small part of that.

Mean Gender Pay Gap                                1%
Median Gender Pay Gap                            2%

Mean Gender Bonus Pay Gap                  32%
Median Gender Bonus Pay Gap               37%

Male                         Female
Proportion of M/F receiving bonus pay                        2%                              15%

Quartile pay band
Lower                                                                                    77%                            23%
Lower Middle                                                                      89%                            11%
Upper Middle                                                                      79%                            21%
Upper                                                                                    90%                            10%

As the Finance Director of Extrastaff Ltd I can confirm that the data set out above is accurate as at 4th April 2019

……………………………………………….

Gary Prince

___________________________________________________________________________________________________________________

MODERN SLAVERY STATEMENT

This statement is made as part of Extrastaff Limited’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act).  It summarises how Extrastaff Limited operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.

This statement is published in accordance with section 54 of the Act, and relates to the financial year January 2019 to December 2019.  It was approved by the board of directors on 1st January 2020.

Steve Hill

Managing Director

Our Business

Extrastaff Limited is an independent limited company operating in the recruitment sector.  We specialise in supplying temporary workers to the driving and industrial sectors.  For details of our Company structure see www.extrastaff.com.

All of the clients we work with, and temporary workers we provide, are known to and identified by our staff in person.  The clients that we provide staff to are located in the midlands and south eastern region of the UK.  The temporary workers we supply live in the same locations.

We are members of the Recruitment and Employment Confederation (www.rec.uk.com), the Freight Transport Association (www.fta.co.uk), the Association of Labour Providers (labourproviders.org.uk)

and we also hold a Gangmaster licence (www.gla.gov.uk).  We continue to work with the Institute of Recruitment Professionals (www.rec-irp.uk.com).

Our Policies

Extrastaff Limited has a modern slavery policy and our modern slavery statement is available at www.extrastaff.com.

Our policies are established by our HR department, based on advice from HR professionals, industry best practice and legal advice and are approved by our Directors.  We review our policies regularly, or as needed to adapt to changes.

Our Processes for Managing Risk

In order to assess the risk of modern slavery, we use the following processes:

  • We continue to review the potential for risk at regular intervals, including the possibility of auditing a supplier or conducting spot checks
  • All applicant interviews and registrations continue to be carried out in person by an Extrastaff employee
  • At the point of registration, right to work checks continue to be conducted along with the requirement of other specific original documentation, not only does this ensure they have a valid statutory excuse to work in the UK, it also confirms they have control of their own documents
  • We consistently carry out regular audits to ensure internal compliance is kept to a high standard
  • We continue to check the names and addresses of our workers as a number of people listing the same address may indicate high shared occupancy, often a factor for those being exploited
  • We are introducing ad hoc welfare calls and surveys to temporary workers to ascertain if they are satisfied with the temporary work provided/locations/working conditions

 Our Training

All our staff receive training and support that is appropriate to their role.  In particular:

  • We continue to provide training in how to conduct right to work checks, discrimination, face to face only interview process, internal policies and procedures
  • We continue to provide awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
  • Training continues to be refreshed regularly.

We are confident that we have sufficient processes and procedures in place to minimalise the risk of human trafficking within our supply chain.  However, we are continuously looking to improve them when deemed necessary and to develop our training programs and policies in line with Company growth and legislation changes.

Since the introduction of this policy we have greatly raised awareness of this important issue with our staff and look forward to building on this solid foundation to eliminate, as much as we reasonably can, modern slavery concerns from our business.

___________________________________________________________________________________________________________________

GDPR Data Protection Policy May 2018

Extrastaff takes the protection of your data seriously. For GDPR purposes please find attached and below our company policy.

Contents

  • Introduction
  • Definitions
  • Data processing under the Data Protection Laws

1.       The data protection principles

2.       Legal bases for processing

3.       Privacy by design and by default

  • Rights of the Individual

1.       Privacy notices

2.       Subject access requests

3.       Rectification

4.       Erasure

5.       Restriction of processing

6.       Data portability

7.       Object to processing

8.       Enforcement of rights

9.       Automated decision making

  • Personal data breaches

1.       Personal data breaches where the Company is the data controller

2.       Personal data breaches where the Company is the data processor

3.       Communicating personal data breaches to individuals

  • The Human Rights Act 1998
  • Complaints

Annex – legal bases for processing personal data

All organisations that process personal data are required to comply with data protection legislation.  This includes in particular the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulation (together the ‘Data Protection Laws’).  The Data Protection Laws give individuals (known as ‘data subjects’) certain rights over their personal data whilst imposing certain obligations on the organisations that process their data.

As a recruitment business, the Company collects and processes both personal data and sensitive personal data.  It is required to do so to comply with other legislation.  It is also required to keep this data for different periods depending on the nature of the data.

This policy sets out how the Company implements the Data Protection Laws. It should be read in conjunction with the Data Protection Procedure.

In this policy, the following terms have the following meanings:

consent means any freely given, specific, informed and unambiguous indication of an individual’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of persona data relating to him or her;

data controller means an individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data;

data processor means an individual or organisation which processes personal data on behalf of the data controller;

personal data* means any information relating to an individual who can be identified, such as by a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data;

processing means any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to an individual without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable individual;

sensitive personal data* means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health, an individual’s sex life or sexual orientation and an individual’s criminal convictions.

* For the purposes of this policy we use the term ‘personal data’ to include ‘sensitive personal data’ except where we specifically need to refer to sensitive personal data.

Supervisory authority means an independent public authority which is responsible for monitoring the application of data protection. In the UK the supervisory authority is the Information Commissioner’s Office (ICO).

All of these definitions are italicised throughout this policy to remind the reader that they are defined terms.

The Company processes personal data in relation to its own staff, work-seekers and individual client contacts and is a data controller for the purposes of the Data Protection Laws. The Company has registered with the ICO and its registration number is Z1519596

The Company may hold personal data on individuals for the following purposes:

  • Staff administration;
  • Advertising, marketing and public relations
  • Accounts and records;
  • Administration and processing of work-seekers’ personal data for the purposes of providing work-finding services, including processing using software solution providers and back office support
  • Administration and processing of clients’ personal data for the purposes of supplying/introducing work-seekers
  1. 1.      The data protection principles 

The Data Protection Laws require the Company acting as either data controller or data processor to process data in accordance with the principles of data protection. These require that personal data is:

  1. Processed lawfully, fairly and in a transparent manner;
  2. Collected for specified and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. Accurate and kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. Kept for no longer than is necessary for the purposes for which the personal data are processed;
  6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures; and that
  7. The data controller shall be responsible for, and be able to demonstrate, compliance with the principles.
  1. 2.      Legal bases for processing

The Company will only process personal data where it has a legal basis for doing so (see Annex A). Where the Company does not have a legal reason for processing personal data any processing will be a breach of the Data Protection Laws.

The Company will review the personal data it holds on a regular basis to ensure it is being lawfully processed and it is accurate, relevant and up to date and those people listed in the Appendix shall be responsible for doing this.

Before transferring personal data to any third party (such as past, current or prospective employers, suppliers, customers and clients, intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back office support)), the Company will establish that it has a legal reason for making the transfer.

  1. 3.      Privacy by design and by default

The Company has implemented measures and procedures that adequately protect the privacy of individuals and ensures that data protection is integral to all processing activities. This includes implementing measures such as:

  • data minimisation (i.e. not keeping data for longer than is necessary);
  • pseudonymisation;
  • anonymization
  • cyber security

The Company shall provide any information relating to data processing to an individual in a concise, transparent, intelligible and easily accessible form, using clear and plain language. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. The Company may provide this information orally if requested to do so by the individual.

  1. 1.       Privacy notices

Where the Company collects personal data from the individual, the Company will give the individual a privacy notice at the time when it first obtains the personal data.

Where the Company collects personal data other than from the individual directly, it will give the individual a privacy notice within a reasonable period after obtaining the personal data, but at the latest within one month.  If the Company intends to disclose the personal data to a third party then the privacy notice will be issued when the personal data are first disclosed (if not issued sooner).

Where the Company intends to further process the personal data for a purpose other than that for which the data was initially collected, the Company will give the individual information on that other purpose and any relevant further information before it does the further processing.

  1. 2.       Subject access requests

The individual is entitled to access their personal data on request from the data controller.

  1. 3.       Rectification

The individual or another data controller at the individual’s request, has the right to ask the Company to rectify any inaccurate or incomplete personal data concerning an individual.

If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to rectify the personal data unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold – however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

  1. 4.       Erasure

The individual or another data controller at the individual’s request, has the right to ask the Company to erase an individual’s personal data. 

If the Company receives a request to erase it will ask the individual if s/he wants his personal data to be removed entirely or whether s/he is happy for his or her details to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise).  The Company cannot keep a record of individuals whose data it has erased so the individual may be contacted again by the Company should the Company come into possession of the individual’s personal data at a later date.

If the Company has made the data public, it shall take reasonable steps to inform other data controllers and data processors processing the personal data to erase the personal data, taking into account available technology and the cost of implementation.

If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to erase the personal data unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold – however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

  1. 5.       Restriction of processing

The individual or a data controller at the individual’s request,has the right to ask the Company to restrict its processing of an individual’s personal data where:

  • The individual challenges the accuracy of the personal data;
  • The processing is unlawful and the individual opposes its erasure;
  • The Company no longer needs the personal data for the purposes of the processing, but the personal data is required for the establishment, exercise or defence of legal claims; or
  • The individual has objected to processing (on the grounds of a public interest or legitimate interest) pending the verification whether the legitimate grounds of the Company override those of the individual.

If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to restrict the personal data unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold – however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

  1. 6.       Data portability

The individual shall have the right to receive personal data concerning him or her, which he or she has provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller in circumstances where:

  • The processing is based on the individual’s consent or a contract; and
  • The processing is carried out by automated means.

Where feasible, the Company will send the personal data to a named third party on the individual’s request.

  1. 7.       Object to processing

The individual has the right to object to their personal data being processed based on a public interest or a legitimate interest. The individual will also be able to object to the profiling of their data based on a public interest or a legitimate interest.

The Company shall cease processing unless it has compelling legitimate grounds to continue to process the personal data which override the individual’s interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

The individual has the right to object to their personal data for direct marketing.

  1. 8.       Enforcement of rights

All requests regarding individual rights should be sent to the person whose details are listed in the Appendix.

The Company shall act upon any subject access request, or any request relating to rectification, erasure, restriction, data portability or objection or automated decision making processes or profiling within one month of receipt of the request. The Company may extend this period for two further months where necessary, taking into account the complexity and the number of requests.

Where the Company considers that a request under this section is manifestly unfounded or excessive due to the request’s repetitive nature the Company may either refuse to act on the request or may charge a reasonable fee taking into account the administrative costs involved.

  1. 9.           Automated decision making

The Company will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:

  • Is necessary for the entering into or performance of a contract between the data controller and the individual;
  • Is authorised by law; or
  • The individual has given their explicit consent.

The Company will not carry out any automated decision-making or profiling using the personal data of a child.

Reporting personal data breaches

All data breaches should be referred to the persons whose details are listed in the Appendix.

  1. 1.       Personal data breaches where the Company is the data controller:

Where the Company establishes that a personal data breach has taken place, the Company will take steps to contain and recover the breach. Where a personal data breach is likely to result in a risk to the rights and freedoms of any individual the Company will notify the ICO.

Where the personal data breach happens outside the UK, the Company shall alert the relevant supervisory authority for data breaches in the effected jurisdiction.

  1. 2.       Personal data breaches where the Company is the data processor:

The Company will alert the relevant data controller as to the personal data breach as soon as they are aware of the breach.

  1. 3.       Communicating personal data breaches to individuals

Where the Company has identified a personal data breach resulting in a high risk to the rights and freedoms of any individual, the Company shall tell all affected individuals without undue delay.

The Company will not be required to tell individuals about the personal data breach where:

  • The Company has implemented appropriate technical and organisational protection measures to the personal data affected by the breach, in particular to make the personal data unintelligible to any person who is not authorised to access it, such as encryption.
  • The Company has taken subsequent measures which ensure that the high risk to the rights and freedoms of the individual is no longer likely to materialise.
  • It would involve disproportionate effort to tell all affected individuals. Instead, the Company shall make a public communication or similar measure to tell all affected individuals.

All individuals have the following rights under the Human Rights Act 1998 (HRA) and in dealing with personal data these should be respected at all times:

  • Right to respect for private and family life (Article 8).
  • Freedom of thought, belief and religion (Article 9).
  • Freedom of expression (Article 10).
  • Freedom of assembly and association (Article 11).
  • Protection from discrimination in respect of rights and freedoms under the HRA (Article 14).

If you have a complaint or suggestion about the Company’s handling of personal data then please contact the person whose details are listed in the Appendix to this policy.

Alternatively, you can contact the ICO directly on 0303 123 1113 or at https://ico.org.uk/global/contact-us/email

a)     The lawfulness of processing conditions for personal data are:

  1. Consent of the individual for one or more specific purposes.
  2. Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
  3. Processing is necessary for compliance with a legal obligation that the controller is subject to.
  4. Processing is necessary to protect the vital interests of the individual or another person.
  5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
  6. Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.

b)     The lawfulness of processing conditions for sensitive personal data are:

  1. Explicit consent of the individual for one or more specified purposes unless reliance on consent is prohibited by EU or Member State law.
  2. Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual.
  3. Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent.
  4. In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
  5. Processing relates to personal data which are manifestly made public by the individual.
  6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
  7. Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
  8. Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.
  9. Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.
  10. Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.

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