About this document
1.1 The Company is aware of its obligations under the General Data Protection Regulation (GDPR), retained in domestic law as the UK GDPR and is committed to processing your data securely and transparently. This privacy notice sets out, in line with UK GDPR, the types of data that we 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
2.1 The Company is a data controller, meaning that it determines the processes to be used when using your personal data. Contact details regarding personal data is as follows: Vanessa Frampton, Human Resources Director Vanessa.email@example.com
Data protection principles
3.1 In relation to your personal data, we will;
Types of data we process
4.1 We hold many types of data about you, including;
How we collect your data
5.1 We collect data about you in a variety of ways including the information you include in a CV, recruitment cover letter, or notes made by us during a recruitment interview. Further information will be collected from you directly such as evidence of your right to work in the UK.
5.2 In some cases, we will collect data from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
5.3 Personal data is kept within the Company’s HR and IT systems.
Why we process your data
6.1 The law on data protection allows us to process your data for a number of lawful basis including;
6.2 All of the processing carried out by us falls into one of the permitted reasons.
6.3 Generally, we will rely on the five reasons set out above to process your data. For example, we need to collect your personal data to ensure we are complying with legal requirements such as:
6.4 We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:
6.5 If you are unsuccessful in obtaining employment, your data will only be used to provide feedback in relation to the specific application and to seek your consent to retain your data should other suitable job vacancies arise in the Company, which we think you may wish to apply. You are free to withhold your consent to this and there will be no consequences for withholding consent.
Special categories of data
7.1 Special categories of data are data relating to your:
7.2 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:
7.3 We will use your special category data:
7.4 We do not need your consent if we use special categories of personal data to carry out our legal obligations or exercise specific rights under employment law.
7.5 However, we may ask you for your consent to process 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.
Criminal conviction data
8.1 We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. For example, we will use criminal conviction data as part of the Fit & Proper Declaration process for Senior and/ or regulated roles in accordance with the FCA.
If you do not provide your data to us
9.1 One of the reasons for processing your data is to allow us to carry out an effective recruitment process. You are under no obligation to provide us with your data, however, we may not be able to process or continue with your application (as appropriate).
10.1 Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties. This includes, for example, the HR department, those who are responsible for screening applications and interviewing within the hiring department and the IT department, where you may be required to undertake assessments.
10.2 We share your data with third parties to obtain references as part of the recruitment process and to log your application on our recruitment tracking system.
10.3 We do not share your data with bodies outside of the European Economic Area.
Protecting your data
11.1 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.
11.2 Where we share your data with third parties, we provide written instructions to them to ensure that your data is held securely and in line with UK 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
12.1 In line with data protection principles, we only keep your data for as long as we need it for and this will depend on if you are successful in obtaining employment with us.
12.2 If your application is not successful we will keep your data for 12 months once the recruitment exercise ends. However, you can withdraw your consent to our processing of your data at any time.
Automated decision making
13.1 No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Your rights in relation to your data
14.1 The law on data protection gives you certain rights in relation to the data we hold on you. These are:
14.2 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.
Making a complaint
15.1 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.
Best Practice IFA Group are registered with the Information Commissioner’s Office under registration number Z954991X
Data protection compliance
16.1 James Lasenby is the Company’s appointed Compliance Officer in respect of its data protection activities. He can be contacted at firstname.lastname@example.org.
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