Job Applicant Privacy Notice
Data Protection Manager: Mark Willson HR Data Champion: Clair Walker
Recruitment Manager: Paul Hayler
Write to: Human Resources, Southeastern, Floor 3, Friars Bridge Court, 41-45 Black Friars Road SE1 8NZ.
As part of any recruitment process, the Company collects and processes personal data relating to job applicants through the recruitment website. The Company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations. Please read the following privacy notice to understand how the Company uses and protects the information you provide.
What information does the Company collect?
The Company 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 Company 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 Company collects this information in a variety of ways. For example, data might be contained in application forms you complete through the Company’s online recruitment system and information you upload such as CV’s. Data may also be obtained from your passport or other identity documents, or collected through interviews or other forms of assessment including online tests and results from assessment centres.
The Company 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. The Company 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 and on other IT systems (including email).
Why does the Company process personal data?
The Company 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 Company 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 Company 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 Company to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. The Company may also need to process data from job applicants to respond to and defend against legal claims.
Where the Company 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 employees or workers and has concluded that they are not.
The Company processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where the Company 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 Company is obliged to seek information about criminal convictions and offences. Where the Company 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.
If your application is unsuccessful, the Company will keep your personal data on file for six months in case there are future employment opportunities for which you may be suited. The Company will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time by you contacting the Recruitment Manager.
Who has access to data?
Your information will be shared internally for the purposes of the recruitment exercise. 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 Company will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The Company 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.
How does the Company protect data?
The Company takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
For how long does the Company keep data?
If your application for employment is unsuccessful, the Company will hold your data on file for six months after the end of the relevant recruitment process. If you agree to allow the Company to keep your personal data on file, the Company may hold your data on file for as part of a recruitment pool for further six months for consideration for future employment opportunities. You may withdraw from the recruitment pool at any time and will be contacted every six months to seek your permission to retain your details.
As per the Company’s Recruitment policy exceptions to the retention of data will be made in the following circumstances:
- For trainee drivers who have failed to meet the required standards regarding assessments, their details will be retained on file for a period of two years.
- For trainee drivers who have failed to meet the required standards regarding assessments on two occasions their details will be retained on the RACF database, as they will not be given a further opportunity to apply for a driver’s position. This is a procedural requirement governed by external agency’s.
- For employees who have been dismissed from the Company details will be retained for a period of five years.
At the end of that period [or once you withdraw your consent], your data will be deleted or destroyed.
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, Including:
- access and obtain a copy of your data on request;
- require the Company to change incorrect or incomplete data;
- require the Company 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 Company is relying on its legitimate interests as the legal ground for processing; and
- ask the Company to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the Company's legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact the Recruitment Manager, who may request you complete a subject access request form.
If you believe that the Company has not complied with your data protection rights, you can complain to either the Recruitment Manager, Data Controller, Data Officer or directly to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the Company during the recruitment process. However, if you do not provide the information, the Company may not be able to process your application or at all.
If you require the fully detailed version of the Job Applicant Privacy Notice, then please request from the Recruitment Manager.