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; and
– Process it in a way that ensures it will not be used for anything that you are not aware of
or have consented to (as appropriate), lost or destroyed.

Types of data we process

We hold many types of data about you, including:
– Your personal details including your name, address, telephone numbers, email address,
date of birth and gender;
– Your marital status;
– Whether or not you have a disability for which the Company needs to make reasonable
adjustments during the recruitment process;
– Information included on your CV/application form and information given during a
recruitment interview, including qualifications, skills, experience, employment history and
references;
– Information about your nationality and documentation relating to your right to work in the
UK;

– Driving licence;
– Criminal records checks; and
– Information about your current level of remuneration, including benefit entitlements.

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/application form or a job application cover letter, 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 right to work evidence/ID documents.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references and Responsible Organisations that check criminal records.

Data will be stored in a range of different places, including on your applicant record, in the
Company’s HR/recruitment systems and in other IT systems (including the Company’s email system).

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 to your data.

For example, 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 applicants and employees.

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 legal obligations and exercise specific rights in relation to employment.

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:

– Processing personal data to allow us to manage the recruitment process;
– Assessing suitability for employment;
– Making decisions about who to offer employment to;
– Making decisions about salary and other benefits; and
– Dealing with legal claims made against us.

We will not use your data for any purpose other than the recruitment exercise for which you have applied.

Special categories of data

Special categories of data are data relating to your:
– Health;
– Sex life;
– Sexual orientation;
– Race;
– Ethnic origin;
– Political opinion;
– Religion;
– 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; and
– You have already made the data public.

We will use your special category data:

– To make reasonable adjustments to the recruitment process.

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.

If you do not provide your data to us

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, we may not be able to process your application properly or at all. If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the UK, access to a satisfactory DBS check and satisfactory references.

Sharing your data

Your data will be shared internally for the purposes of the recruitment exercise. This includes, for example, members of the team involved in HR and recruitment, interviewers involved in the recruitment process, managers in the Company and IT staff if access to the data is necessary for the performance of their roles. Your data will also be shared with our external HR consultants.

In some cases, we will collect data about you from third parties, such as employment agencies.

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 and perform criminal records checks as part of the recruitment process.

We will not transfer your data outside the European Economic Area.

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. All hard copies/paper copies are stored in locked filing cabinets with restricted access. All keys to access are held securely by senior management. Where electronic personnel files/files containing sensitive information are uploaded to a shared drive, access restrictions are in place. Access is limited to senior management or Head Office. Any hard copies/paper copies that are
transported, will always be within a security sealed document bag.

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 successful, your data will be kept and transferred to your personnel file. We have a separate privacy notice for employees, which will be provided to you.

If your application for employment is unsuccessful, we will hold your data on file for six months after the end of the relevant recruitment process. 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 a further three months.

At the end of the retention period, or once you withdraw your consent, your data is deleted or destroyed.

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

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; and
– 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 ti**@cl**.org

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.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any updates. We will also notify you in other ways from time to time about the processing of your personal information.