Data protection for venues
Your responsibilities for workers' personal data, and how to handle their requests.
Who's responsible
Fairpool holds your workers' names, roles, weights, hours and tip shares. For this data, your business is the controller. That means you decide what's recorded and why, and you're responsible for it under UK data protection law.
Fairpool is your processor: we store and use the data only on your instructions, under our data processing agreement.
What you need to do
- Tell your workers that you use Fairpool to work out and record tips, for example in your staff privacy notice.
- Your reason for keeping tip records is that the law requires them.
- Only record what's needed. Don't put sensitive details, such as health information, in notes.
- Keep your password private. If you think someone else has it, change it and press Sign out everywhere on the Account page.
- Keep worker links private. Replace any link that's been sent to the wrong person.
When a worker asks for a copy of their data
This is called a subject access request. You normally have one month to reply.
- Open the worker's page.
- Under Their data, press Download their data (JSON). JSON is a standard data file.
- Send it to them, along with anything else you hold about them outside Fairpool.
This is different from a request for tip records under the Tips Act, which has a 4-week deadline. See Sharing records with workers.
When a worker asks you to erase their data
You must keep tip records for 3 years, so you usually can't delete them completely. Fairpool handles this for you:
- If the worker has no hours or tip shares, they're deleted completely.
- If they do, their name is replaced with an anonymous label and the amounts are kept. These are deleted automatically when the 3 years are up.
- Open the worker's page.
- Under Erase this worker, type their name to confirm.
- Press Anonymise worker or Delete worker. This can't be undone.
Complaints
If a worker is unhappy with how you've handled their data, try to sort it out with them first. They can also complain to the Information Commissioner's Office. For how Fairpool itself handles data, see our privacy notice.