Employee Privacy Notice — template for FieldFlow customers
This is a template for FieldFlow customers to adapt and give to their workers. Replace everything [in brackets]. The company using FieldFlow — not FixFlex — is responsible for this notice and for the lawful basis of its processing. Where location and attendance monitoring is involved, the ICO recommends completing a data protection impact assessment (DPIA) first.
Privacy notice for workers — [Company name]
[Company name] ([address], [contact email]) uses the FieldFlow app to manage projects, attendance, pay and invoicing. We are the controller of your personal data. This notice explains what the app records about you.
What we record
| Data | Why | Lawful basis |
|---|---|---|
| Name, date of birth, address, phone, email, National Insurance number, UTR, pay type, rates and payments, CIS status and deductions | To employ or engage you, pay you and meet HMRC and CIS obligations | Contract; legal obligation |
| Clock-in and clock-out times, the project, how you clocked in (QR, NFC, photo or manual), hours and confirmations by a site manager | To record working time, pay you correctly and meet working-time rules | Contract; legal obligation |
| GPS position — only at the moment you clock in and clock out. The app flags entries made far from the site. It does not track you at any other time. | To confirm attendance on site and prevent time fraud | Legitimate interests [summarise your assessment] |
| Photos: attendance photos (if we use photo clock-in), receipt and site photos you take | Attendance evidence; expenses; project records | Legitimate interests; contract |
| Leave requests, including sickness absence (health information) | To manage holiday, sick pay and absence | Contract; legal obligation. For sickness: employment law obligations (UK GDPR Art. 9(2)(b), DPA 2018 Sch. 1 para 1) |
| Tasks, messages and notes in the app | To organise work on site | Legitimate interests |
| Fingerprint or face unlock | To lock the app on your phone | Handled only by your phone's operating system. We never receive any biometric data — the app only learns whether unlocking succeeded. |
Where it is kept and who can see it
- On our company's phones in an encrypted database, and synced between them end-to-end encrypted. FieldFlow's maker, FixFlex Ltd, relays the encrypted data but cannot read it.
- Who can see what depends on role: [admins see everything; site managers see attendance and tasks for their sites; workers see their own time, tasks and payments].
- We share data with HMRC [and our accountant / payroll provider] where required.
How long we keep it
[e.g. pay and tax records: 6 years after the end of the tax year; attendance records: 2 years; GPS points: X months; sickness records: duration of employment + X years]
Your rights
You can ask to see your data, have it corrected or deleted, restrict or object to its use, or receive a copy. Contact [contact email]. If you're not satisfied, you can complain to the ICO: ico.org.uk/make-a-complaint, 0303 123 1113.