Privacy Manager Europe: Stephanie Durrant – +44 1922 610 000
Privacy Manager US: Melissa Hughes – 1-636-587-1941
As part of any recruitment process, the organisation collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does the organisation collect?
The organisation collects a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
The organisation collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
The organisation will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks (if applicable to the job role). The organisation will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems, on external recruitment sites, and on other IT systems, including email.
Why does the organisation process personal data?
The organisation needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
The organisation has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.
Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of prospective employees and has concluded that they are not.
The organisation processes health information to assess the need to make reasonable adjustments to the recruitment process for candidates who have a disability. Where the organisation processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.
For some roles, the organisation is obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment. The organisation processes such information in accordance with applicable laws.
If your application is unsuccessful, the organisation will keep your personal data on file in case there are future employment opportunities for which you may be suited. The organisation will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time. While you are free to withdraw consent, the organisation may need to retain your personal information for other reasons noted above.
Who has access to data?
Your information will be shared internally for the purposes of recruitment. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff, if access to the data is necessary for the performance of their roles.
The organisation will not share your data with third parties unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks (if applicable to the role).
Please be informed that your data may be transferred outside the EEA, namely the United States of America, where the organisation’s parent company is based. Data is transferred outside the EEA only in compliance with applicable privacy laws.
How does the organisation protect data?
The organisation has internal policies and controls in place to reduce risks related to losing, accidentally destroying, misusing or disclosing, and allowing unauthorised access to your personal data. Data stored on our servers is password protected with individual logs on details and personal identifications. Electronic data passed throughout the business via attachments will be password protected. Any work documents containing personal data will require a password to access. Servers are in a lockable room that only assigned personnel may access.
How long does the organisation keep data?
Personal data is kept as long as necessary for the purposes for which it was collected, including to comply with applicable laws. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- request that the organisation change incorrect or incomplete data;
- request that the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing;
- ask that the organisation provides your data in a machine-readable format for the purpose of transmitting it to another party; and
- ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation’s legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact Stephanie Durrant, HR Director. Subject access request forms are available on request.
If you believe that the organisation has not complied with your data protection rights, you can contact your local data protection authority to investigate your complaint further.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.
Recruitment processes are not based solely on automated decision-making.