Recruitment Privacy Policy
RECRUITMENT PRIVACY POLICY
The Company 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 Company is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: Robert West Consulting Ltd, Delta House, 175-177 Borough High Street, London, SE1 1HR.
Data protection principles
In relation to your personal data, we will:
Types of data we process:
We hold many types of data about you, including:
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, or notes made by our recruiter during a recruitment interview. Further information will be collected directly from you on Form 33 – Application form for external applicants.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references.
Personal data is kept in personnel files within the Company’s HR and IT systems (including emails).
Why we process your data:
The law on data protection allows us to process your data for certain reasons only:
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:
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:
If you are unsuccessful in obtaining employment, we will seek your consent to retaining your data in case other suitable job vacancies arise in the Company for 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:
Special categories of data are data relating to your:
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:
We will use your special category data:
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.
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 rely on the lawful basis of legal obligation to process this data.
If you do not provide your data to us
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all
Sharing your data
Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties with regard to recruitment.
Your data will be shared with third parties if you are successful in your job application.
If you are offered a position with us your data will be shared with third parties in order to complete the pre-employment checks.
Protecting 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 destroy, misused or disclosed.
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 twelve 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 twelve months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdraw 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.
Automated decision making
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
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
If you wish to exercise any of the rights explained above, please contact the Managing Director.
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.