What is the purpose of this policy?
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Data protection principles
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you
There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you:
- Personal details such as name, title, date of birth, gender, marital status, dependents, next of kin, emergency contact information;
- Contact details such as addresses, telephone numbers, and personal email addresses;
- Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process);
- Employment history and qualifications;
- Any information you give to us during any interview;
- CCTV footage and visitor books
- Information about your ethnicity, disability and medical or health
- CCJ, bankruptcy and insolvency
- Information about criminal convictions and offences.
How is your personal information collected?
How we will use personal information about you
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
- Making a decision about your recruitment or appointment
- Determining the terms on which you work for us, for example, part-time hours
- Assessing your skills, qualifications and suitability for a particular job or task, including decisions about promotions
- Communicate with you about the recruitment process
- Checking you are legally entitled to work in the UK
- Carrying out background and reference checks where applicable
- Complying with health and safety obligations
- Complying with legal or regulatory requirements
- Dealing with legal disputes involving you, or other candidates, employees, workers and contractors
- To prevent fraud
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
- Equal opportunities
Having received your CV and covering letter or your application form and the results from the test which you took where applicable, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the work. If we decide to offer you the work, we will then take up references and/or carry out a criminal record and/or carry out any other background check before confirming your appointment.
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
Change of purpose
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information about you
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations or exercise rights in connection with employment.
- Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme, and in line with our data protection policy.
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
- Where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
- 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 a test or
- 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.
Do we need your consent?
Information about criminal convictions
We will collect information about your criminal convictions history if we would like to offer you the work (conditional on checks and any other conditions, such as references, being satisfactory). We are required to carry out a 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 we are legally required by Financial Conduct Authority to carry out criminal record checks for those carrying out certain work.
We are allowed to use your personal information in this way to carry out our obligations.
Automated decision making
- Where we have notified you of the decision and given you 21 days to request a reconsideration.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Sharing your information with third parties and other group entities
Transferring information outside the EU
However, we as data controller, are under an obligation to ensure that such transfers are performed in a manner that ensures that your personal information is adequately protected. Therefore to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.
Below sets out the current transfers we have in place and the safeguard mechanisms in place:
|Purpose of transfer||Details of the transfer||Safeguard mechanism in place|
|Assessments carried out as part of the recruitment process||
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
- For unsuccessful candidate data – 1 year after the recruitment process has finished
- Visitor logs – 2 months from completion of each visitor book
Rights of access, correction, erasure and restriction
Under data protection law, when personal information is being transferred outside the EEA, we as data controller, are under an obligation to ensure that such transfers are performed in a manner that ensures that your personal information is adequately protected.
In the event that we transfer your personal information outside of the EEA, we will always put in place adequate safeguards to ensure that your personal information is protected.
Adequate safeguards may include placing contractual obligations on the third party that we are transferring your information to or ensuring that the third party is certified to the EU-US Privacy Shield Framework, if we are making transfers to third parties located in the United States.
How long we keep your information for
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing
- Request the transfer of your personal information to another party, also known as data portability.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent