Job applicant privacy notice
The Charity is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with GDPR, the types of data that we collect and hold on you as a job applicant. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
Data controller details
The Charity is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: Canine Partners, Mill Lane, Heyshott, West Sussex, GU29 0ED
Data protection principles
In relation to your personal data, we will:
- process it fairly, lawfully and in a clear, transparent way
- collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
- only use it in the way that we have told you about
- ensure it is correct and up to date
- keep your data for only as long as we need it
- process it in a way that ensures it will not be used for anything that you are not aware of or have not consented to (as appropriate)
- process it in a way that ensures it will not be lost or destroyed
Definition of data processing
Processing covers a wide range of operations performed on personal data, including by manual or automated means. It includes the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.
The General Data Protection Regulation (GDPR) applies to the processing of personal data wholly or partly by automated means as well as to non-automated processing, if it is part of a structured filing system.
Types of data we process
We hold many types of data about you, including:
- your personal details including your name, address, date of birth, email address, phone numbers
- your photograph
- marital status
- whether or not you have a disability
- information included on your CV or application form including references, education, academic history, professional qualification, employment history and criminal convictions
- documentation relating to your right to work in the UK
- driving licence
- psychometric tests results (such as a situational judgement test, ability or personality test), interview notes (face to face, telephone or video), behavioural assessments (such as a role play, group exercise or presentation), technical assessments
- pre-employment screening activities carried out for the purposes of criminal records checks, adverse media check.
How we collect your data
We collect data about you in a variety of ways including the information you would normally include in a CV or a job application cover letter, interview test results or notes made by our recruiting officers during a recruitment interview. Further information will be collected directly from you when you complete forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other rights to work evidence.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers or referees when gathering references or credit reference agencies, or when a colleague recommends that we consider you for a position. We may collect data from other sources where you have made your personal information publically available for the purposes of recruitment only on jobs boards, LinkedIn (or other publically available employment-related social media networks and databases for the purposes of headhunting suitable candidates). If you provide links to your personal web pages or social media pages in support of your application, we may review these as part of our selection process.
Personal data is kept in personnel files or within the Charity’s HR and IT systems.
Why we process your data
The law on data protection allows us to process your data for certain reasons only:
- in order to perform the employment contract that we are party to
- in order to carry out legally required duties
- in order for us to carry out our legitimate interests
- to protect your interests and
- where something is done in the public interest.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
We need to collect your data to ensure we are complying with legal requirements such as:
- carrying out checks in relation to your right to work in the UK and
- making reasonable adjustments for disabled candidates.
We also collect data so that we can carry out activities which are in the legitimate interests of the Charity. We have set these out below:
- making decisions about who to offer employment to
- making decisions about salary and other benefits
- assessing training needs
- dealing with legal claims made against us
If you are unsuccessful in obtaining employment, your data will not be used for any reason other than in the ways explaining in relation to the specific application you have made. If you wish to be kept up to date with upcoming vacancies, you can opt in to our job alert.
Special categories of data
Special categories of data are data relating to your:
- sex life
- sexual orientation
- ethnic origin
- political opinion
- trade union membership and
- genetic and biometric data.
We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
- you have given explicit consent to the processing
- we must process the data in order to carry out our legal obligations
- we must process data for reasons of substantial public interest
- you have already made the data public.
We will use your special category data:
- for the purposes of equal opportunities monitoring
- making reasonable adjustments for disabled candidates
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
Criminal conviction data
We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment should you be successful in obtaining employment. We use criminal conviction data in the following ways:
- To assess your suitability to work with the vulnerable adults we support
We process this data because of our legal obligation when recruiting for a role for which checks are authorised by law, for example, roles involving work with vulnerable adults or children where a Disclosure and Barring Service check is required, and our obligation to ensure the safeguarding of children and vulnerable adults and where necessary for the purposes of performing or exercising employment law obligations or rights. We will not request criminal conviction data until the appropriate stage in the recruitment process.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not be able to process or continue with (as appropriate), your application.
Sharing your data
Your data will be shared with colleagues within the Charity where it is necessary for them to undertake their duties with regard to recruitment. This includes, for example, the HR department, those in the department where the vacancy is who responsible for screening your application and interviewing you, the IT department where you require access to our systems to undertake any assessments requiring IT equipment. The Director of Finance & Resources and the Finance & IT Manager have access to your recruitment data.
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information outside the Charity include: Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us, parties who process data on our behalf, which may include: IT support, storage service providers including cloud, background screening providers, Legal and professional advisers, Insurers, our Applicant Tracking System provider.
In some cases, we will collect data about you from third parties, such as employment agencies, your referees, the provider of our Applicant Tracking System. Our Applicant Tracking System provider has a separate Privacy Notice which can be found here https://www.easywebgroup.co.uk/privacypolicy/
Your data will be shared with third parties if you are successful in your job application. In these circumstances, we will share your data in order to obtain references as part of the recruitment process, to obtain a criminal record check.
We do not share your data with bodies outside of the European Economic Area.
However, third parties may share your data with bodies outside of the European Economic Area for the purpose of software development. In such circumstances, the third parties concerned do so in line with GDPR requirements.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such in line with GDPR requirements.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for and this will depend on whether or not you are successful in obtaining employment with us.
If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for 12 months once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for 12 months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
We will make some decisions about you based on automated decision-making (where a decision is taken about you using an electronic system without human involvement). For example, automated decision making is used on initial pre-application question pages to determine if you meet the minimum requirements of the vacancy. If you do not meet the minimum requirements of the vacancy, you will not be able to continue with your application. Any automated decisions will be highlighted to you in the application process and you will be required to agree that you are happy to proceed using this process.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
- the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
- the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
- the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
- the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
- the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- the right to portability. You may transfer the data that we hold on you for your own purposes
- the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
- the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in a way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact the Charity’s Data Protection Compliance Officer.
Making a complaint
The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.
Data Protection Officer
The Charity’s Data Protection Compliance Officer is the Finance & IT Manager. They can be contacted on via the recruitment team at firstname.lastname@example.org. Please address your email to the Data Protection Compliance Officer.