GDPR Privacy Notice for Recruitment
This privacy notice will inform you as to how we look after your personal data when you interact with us directly or you visit our website (regardless of where you visit it from). We are required to notify you of this information under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
The Company has appointed a Data Compliance Contact to oversee compliance with this privacy notice. If you have any questions about this privacy notice or about how we handle your personal information, please contact us at email@example.com.
Data Protection Principles
The Company will comply with the data protection principles when gathering and using personal information, which means that your personal information will be:
- processed lawfully, fairly and in a transparent manner.
- collected only for legitimate purposes that have been clearly explained to you and not further processed in a way that is incompatible with those purposes.
- adequate, relevant and limited to what is necessary in relation to those purposes.
- accurate and, where necessary, kept up to date.
- kept in a form which permits your identification for no longer than is necessary for those purposes.
- processed in a way that ensures appropriate security of the data.
Who Collects The Information
The Company is a ‘data controller’ and gathers and uses certain information about you. In this notice, references to ‘we’ or ‘us’ mean the Company.
What types of personal information do we collect about you?
- your name and contact details (ie address, home and mobile phone numbers, email address);
- details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests;
- your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs;
- information regarding your criminal record;
- details about your disability status;
- details of your referees.
- proof of right to work in the UK documentation
We may also collect the following information after the shortlisting stage, and before making a final decision to recruit:
- information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers;
- information regarding your academic and professional qualifications;
- information regarding your criminal record;
- your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
- a copy of your driving licence and relevant DVLA licence checks.
How Do We Collect Your Personal Information?
We may collect this information from you, your referees (details of whom you will have provided), your education provider, the relevant professional body, the recruitment agency that introduces you to us, DVLA and the Home Office.
Why And How Do We Use Your Personal Information?
We will typically collect and use this information for the following purposes:
- to take steps to enter into a contract;
- for compliance with a legal obligation (eg our obligation to check that you are eligible to work in the United Kingdom);
- for the performance of a task carried out in the public interest; and
- for the purposes of our legitimate interests, but only if these are not overridden by your interests, rights or freedoms.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
What If You Fail To Provide Personal Information?
If you fail to provide certain personal information when requested or required, we may not be able to process your application, or we may be prevented from complying with our legal obligations. You may also be unable to exercise your statutory or contractual rights.
Why And How Do We Use Your Sensitive Personal Information?
We will use your particularly sensitive personal information in the following ways:
- we will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
- we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
We may collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We will carry out an appropriate criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular certain roles within our business require a high degree of trust and integrity since they involve dealing with high value client money and so we would like to ask you to seek a basic disclosure of your criminal records history if this is relevant to your application.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Where Information May Be Held
Information may be held at our offices and those of our group companies, and third party agencies, service providers, representatives and agents as described above.
Who Has Access To Your Personal Information?
Your personal information may be shared internally within the Company, if access to your personal information is necessary for the performance of their roles.
The Company may also share your personal information with third-party service providers (and their designated agents), including:
- professional advisers, such as lawyers and accountants
How We May Share The Information
We may also need to share some of the above categories of personal information with other parties, such as HR consultants and professional advisers. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information with our regulators or as required to comply with the law.
Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How Long We Keep Your Information
We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.
We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised, and the longer period for which they will be kept.
If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment. Our data protection privacy notice for employees will apply.
Your Rights In Connection With Your Personal Information
It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes, e.g. you change your home address, during your working relationship with the Company so that our records can be updated. The Company cannot be held responsible for any errors in your personal information in this regard unless you have notified the Company of the relevant change.
As a data subject, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:
- request access to your personal information – this is usually known as making a data subject access request and it enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
- request rectification of your personal information – this enables you to have any inaccurate or incomplete personal information we hold about you corrected
- request the erasure of your personal information – this enables you to ask us to delete or remove your personal information where there’s no compelling reason for its continued processing, e.g. it’s no longer necessary in relation to the purpose for which it was originally collected
- restrict the processing of your personal information – this enables you to ask us to suspend the processing of your personal information, e.g. if you contest its accuracy and so want us to verify its accuracy
- object to the processing of your personal information – this enables you to ask us to stop processing your personal information where we are relying on the legitimate interests of the business as our legal basis for processing and there is something relating to your particular situation which makes you decide to object to processing on this ground
- data portability – this gives you the right to request the transfer of your personal information to another party so that you can reuse it across different services for your own purposes.
If you wish to exercise any of these rights, please contact our Data Compliance Contact firstname.lastname@example.org. We may need to request specific information from you in order to verify your identity and check your right to access the personal information or to exercise any of your other rights. This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.
If you believe that the Company has not complied with your data protection rights, you can submit your complaint in writing at email@example.com. If you remain dissatisfied with our actions, you have the right to lodge a complaint with the Supervisory Authority – The Information Commissioner’s Office (ICO) at any time.
Transferring Personal Information Outside The European Economic Area
The Company will not transfer your personal information to countries outside the European Economic Area.
Changes To This Privacy Notice
The Company reserves the right to update or amend this privacy notice at any time. We will issue you with a new privacy notice when we make significant updates or amendments. We may also notify you about the processing of your personal information in other ways.
If you have any questions about this privacy notice or how we handle your personal information, please contact our Data Compliance Contact at firstname.lastname@example.org.