What information do we collect?
We collect 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;
- information on your protected characteristics;
- whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process; and
- information about your entitlement to work in the UK.
We may collect 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 and other forms of assessment including selection tests.
We may also collect personal data about you from third parties, such as references supplied by former employers.
Data will be stored in a range of different places, including on your application record, in HR management systems, in the HR filing system and on other IT systems (including email).
Why do we process personal data?
We need to process data to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you.
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts.
We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide who to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
We may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. We process such information to carry out our obligations and exercise specific rights in relation to employment.
For some roles, we are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.
Who has access to your data?
Your information may be shared internally for the purposes of the recruitment process. 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.
We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, employment background checks providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
We will not transfer your data outside the European Economic Area.
How do we protect your data?
We take the security of your data seriously. We have 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 do we keep your data?
If your application for employment is unsuccessful, we will hold your data on file for 2 years after the end of the relevant recruitment process. At the end of that period your data is 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.
Your rights
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require us to change incorrect or incomplete data;
- require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
- object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing.
If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
Automated decision-making
Some of our recruitment processes are based solely on automated decision-making. This is limited to the automatic rejection of candidates who do not have the right to work in the European Union, or where a candidate does not possess the necessary professional qualification for a role.
