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    Worker Privacy Notice

    Effective 17 October 2026 · Version 1.0

    This notice covers workers, employees and agency workers whose employer or contractor uses Saral, including the Saral portal and mobile app. If you are a business subscribing to Saral, see the customer privacy notice.

    1. Who Is Responsible for Your Data

    Your employer or the company that engages you is the data controller. They decide what is collected about you and why, and they are the first point of contact for any question or request about your data. Saral is the software they use to do it. Saral is operated by Deshwal & Co. (the trading name of Vikas Deshwal, England), who acts as your employer’s data processor: we process your data only to provide the service, on your employer’s instructions, and never for our own purposes. If you contact us directly at accounts@getsaral.co.uk, we will refer your request to your employer and help them answer it.

    2. What Data Is Collected

    Depending on which features your employer uses, your record in Saral can hold:

    • Identity: full name, date of birth, nationality, home address, phone number, email address, emergency contact
    • Right to work: passport, biometric residence permit or visa, Home Office share code and the result of the check
    • Tax references: National Insurance number, Unique Taxpayer Reference (UTR), CIS verification status
    • Bank account details for paying you (account name, sort code, account number). The account number is shown masked on screen, and every time an office user reveals the full number it is recorded
    • Proof of address, accreditation and training documents (CSCS card, CITB certificate and similar), and if you contract through your own limited company, its details
    • Your profile photo, if you agree to provide one (see section 3)
    • Attendance: when you checked in and out, which site, how the check-in was made, and the paid time worked out from it; your timesheets and, for CIS subcontractors, the invoices raised from them
    • Location: the single point where your phone was when you checked in by GPS, and site arrivals and departures where your employer has set up geofenced sites (see section 3)
    • Health information you declare on the starter form (injuries or medical conditions relevant to site safety), sickness forms, and any HR case your employer records
    • Leave, training, kit issued to you, and contract documents you sign, with your electronic signature, IP address and the time of signing

    Where your employer uploads a certificate or identity document, Saral may read it with an AI service (Anthropic) to fill in the record; a person at your employer confirms what was read. Saral does not process payroll and does not file any return — payslips, P60s and HMRC returns come from your employer’s payroll and accounting software, not from Saral.

    3. App Permissions, Photos and Face Check-in

    The Saral portal and mobile app can ask for the following device permissions. Each is used only for the purpose described:

    Camera

    Used to scan the QR code or tap the NFC sticker at a site for check-in and check-out — for a scan, only the code value is read and no image is kept. Where your employer has switched on face check-in and you have agreed to it, the camera also takes a photo at each check-in and compares it with your profile photo, with a liveness check so a picture of you cannot be used instead. The comparison is performed on our behalf by Microsoft Azure AI Face. That check-in photo is kept for 90 days and then deleted automatically. Your profile photo is kept until you change or remove it, withdraw your agreement or leave. Where walk-up identification is enabled for your site, a face template made from your profile photo is held by Microsoft Azure in a group belonging only to your employer, and is deleted when you leave or withdraw. You can say no: if you would rather not use your face, you are given a card to tap instead, with no disadvantage, and your employer cannot ask again on the same wording. You can change or remove your photo, or withdraw your agreement, at any time from your profile in the portal.

    Location (including Background Location)

    Used, where your employer has enabled GPS check-in or geofenced sites, to record the point where you checked in and to detect when you arrive at or leave a site (a defined zone around each site), so check-in and check-out can happen automatically.

    • What is stored is the location of each check-in or site arrival/departure — not a continuous trail of your movements.
    • Your recent check-in points (up to 60 days) are compared with each new one to detect a spoofed or replayed location; the result is a flag on the check-in for your manager to review.
    • A check-in made without a location is still recorded and goes to your manager for confirmation; you are never refused for having location off.
    • Background location (“Allow all the time”) is only requested by the mobile app where geofenced sites are in use, so that arrivals and departures are detected while the app is not on screen.

    A persistent notification is displayed on your device whenever the geofence monitor is active, so it is visible at all times that the service is running. Check-in points that are not behind an attendance record are deleted after 24 months; a point behind an attendance record is kept as long as the record.

    Push Notifications

    Used to send you alerts such as check-in reminders, timesheet and attendance confirmations, leave decisions, training and document requests, and messages from your employer. Notifications are delivered through your device’s push service (Google, Apple or Mozilla). You can disable them at any time in your device settings.

    4. Why Your Data Is Processed (Lawful Basis)

    Contract — most data is needed to engage and pay you: recording your attendance, approving your timesheets, producing CIS invoices, holding your bank details for payment, and keeping the records of it.

    Legal obligation — your employer must check your right to work in the UK and keep evidence of it, and must keep accurate records under the Construction Industry Scheme and tax law.

    Legitimate interests — emergency contact details and site-safety declarations protect you and others on site; location at check-in and site arrival/departure records attendance accurately and deters fraud, balanced against your right to privacy and limited to the points described in section 3.

    Explicit consent — your profile photo and any face comparison or face template (special category biometric data) are processed only if you agree, with a card as the alternative and the right to withdraw at any time. Health information is processed under employment-law and health-and-safety obligations.

    5. Who Can See Your Data, and Where It Is Stored

    Your employer’s office users — the people your employer has given HR, attendance, payroll-preparation or site-management roles — see your record according to their role; site managers see the check-in photos only through the exceptions queue. You see your own record in the portal. Saral’s operators cannot sign in as you or your employer and have no way to browse records inside the application; they access data only to support your employer or keep the service running, and platform administration actions require two-step verification and are logged. Your data is stored in the EU (Supabase on AWS, Ireland); the application runs on servers in Dublin. Documents you upload (passport, proof of address and similar), photos and signatures are kept in private storage, opened only through links that expire within an hour; bank account numbers are masked on screen with every full reveal recorded; and every change to your record is written to a tamper-evident audit trail.

    6. How Long Your Data Is Kept

    Your record, documents, attendance and invoices (identity, NI, UTR, bank details, right-to-work evidence, signed contracts, health declarations, HR cases) — kept for as long as your employer subscribes to Saral and for the period your employer sets, which is never shorter than the statutory minimum: six years after the tax year for CIS and payment records, and two years after your engagement ends for right-to-work evidence. Leaving does not delete your record; your employer can delete it on request once no legal duty requires it to be kept.

    Check-in photos — deleted automatically after 90 days. Profile photo and face template — deleted when you remove the photo, withdraw your agreement or leave.

    Check-in location points not behind an attendance record — deleted automatically after 24 months. Records of who viewed your full bank account number and the audit trail of changes to your record — kept for 7 years.

    When your employer’s subscription ends, all of their data in Saral, including your record, is permanently deleted 90 days later, with reminders to them before it happens.

    7. Who Your Data Is Shared With

    Your data is never sold or used for marketing. It is shared only as your employer instructs, with:

    • HMRC — your name, UTR, NI or company number and address, to verify your CIS status when you are engaged as a subcontractor
    • The Home Office (UK Visas and Immigration) — your share code and date of birth, to check your right to work
    • Xero — your employer’s accounting system, which receives you as a supplier contact and your approved CIS invoices and payments
    • Your employer’s accountant or payroll provider — for payment and payroll, in their own systems
    • Site clients — limited to name, trade and accreditation status for site access, where your employer shares it
    • DVLA — if you drive for your employer and give your consent, your licence number, name and date of birth for a licence check

    Saral also uses service providers to run the platform — the database and file storage, email and text messages, push notifications, AI reading of documents, face comparison and error monitoring. Each is bound by a data processing agreement, and the full current list, with what each can see and where it processes, is public at /subprocessors; the controls that protect your data are described on /trust. Where a provider is outside the UK, transfers rest on adequacy regulations or the UK Addendum to the standard contractual clauses.

    8. Your Rights

    Under UK GDPR you have the right to:

    • Access — a copy of the personal data held about you
    • Correction — have inaccurate or incomplete data corrected; you can update many of your own details in the portal
    • Erasure — deletion of your data where no legal obligation requires it to be kept (CIS and right-to-work records must be kept for their statutory periods; the audit trail is kept for 7 years as evidence)
    • Restriction — restriction of processing while a dispute is resolved
    • Portability — your data in a structured, machine-readable format
    • Objection — object to processing based on legitimate interests
    • Withdraw consent — remove your photo and withdraw from face check-in at any time from your profile, with a card as the alternative

    To exercise any of these rights, ask your employer — they are the controller and have the tools to act in Saral. If you write to Saral at accounts@getsaral.co.uk, we will pass your request to your employer and assist them so that you receive a response within one month, as the law requires.

    9. Complaints

    If you believe your data has not been handled correctly, raise it with your employer first. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

    10. Changes to This Notice

    This notice may be updated from time to time, and the latest version is always at this page. Where a change is significant — for example a new use of your photo — you are told in the portal, and a change to what you agreed to is asked for again before it applies.

    Saral is operated by Deshwal & Co., England  |  Your employer is the controller; Saral is its processor