In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, as prospective employees of our Company, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
We keep several categories of personal data on our prospective employees in order to carry out effective and efficient processes. We keep this data in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example, recruitment logs.
Specifically, we hold the following types of data:
You provide several pieces of data to us directly during the recruitment exercise. In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
Should you be successful in your job application, we will gather further information from you, for example, your bank details, medical information and next of kin details, once your employment begins.
The law on data protection allows us to process your data for certain reasons only. The information below categorises the types of data processing we undertake and the lawful basis we rely on.
|Activity requiring your data||Lawful basis|
|Carrying out checks in relation to your right to work in the UK||Legal obligation|
|Making reasonable adjustments for disabled employees||Legal obligation|
|Obtaining evidence of Coronavirus vaccinations and boosters, or medical exemption evidence (from 11 November 2021)||Legal obligation|
|Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion||Our legitimate interests|
|Making decisions about salary and other benefits||Our legitimate interests|
|Making decisions about contractual benefits to provide to you||Our legitimate interests|
|Using DocuSign to send/receive documents and information to your personal email address relating to the recruitment process documentation and employment documents||Our legitimate interests|
|Assessing training needs||Our legitimate interests|
|Dealing with legal claims made against us||Our legitimate interests|
|Preventing fraud||Our legitimate interests|
Special categories of data are data relating to your:
We carry out processing activities using special category data:
Most commonly, we will process special categories of data when the following applies:
In most cases, any special categories of data are not given at the job application stage, however, you may have chosen to give us information relating to these categories during the application stage in which case the above may apply.
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment or administer contractual benefits.
We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability or your continued suitability for the role. We rely on the lawful basis of our legal obligation to process this data.
Employees within our company who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with GDPR.
Data is shared with third parties for the following reasons:
We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We do not share your data with bodies outside of the European Economic Area.
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
We only keep your data for as long as we need it for, which, in relation to unsuccessful candidates, is one year.
If your application is not successful and we have not sought consent, or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for six months once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for nine months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
Automated decision-making means making decisions about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
You have the following rights in relation to the personal data we hold on you:
In addition to the above rights, you also have the unrestricted right to withdraw consent, that you have previously provided, to our processing of your data at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact our Data Protection Officer, details of which are at the end of this policy.
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
Our Data Protection Officer is: