Candidate Privacy Statement
As part of the recruitment process, we will collect and process personal data about you. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
WHAT INFORMATION DOES THE ORGANISATION COLLECT?
The organisation collects a range of information about you including:
- 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;
- whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.
For further details please see Appendix 1
The organisation collects 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 or other forms of assessment, including online tests.
The organisation will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. The organisation will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
WHY DOES THE ORGANISATION PROCESS PERSONAL DATA?
The organisation needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.
The organisation has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.
Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
The organisation processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where the organisation processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.
For some roles, the organisation is obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
If your application is unsuccessful, the organisation will keep your personal data on file in case there are future employment opportunities for which you may be suited. The organisation will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
WHO HAS ACCESS TO DATA?
Your information will be shared internally for the purposes of the recruitment exercise. 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.
The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
HOW DOES THE ORGANISATION PROTECT DATA?
FOR HOW LONG DOES THE ORGANISATION KEEP DATA?
If your application for employment is unsuccessful, the organisation will hold your data on file for a period of 6 months (or 12 months if you have applied online), after the end of the relevant recruitment process for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data is deleted or destroyed. If you have applied online you will be asked on an annual basis if you would like us to hold your data online for a further 12 month period.
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 the Employee Data 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 the organisation to change incorrect or incomplete data;
- require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and
- ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation's legitimate grounds for processing data.
If you would like to exercise any of these rights, or if you would like to make a subject access request, please refer to the table below for guidance as to the applicable reporting requirements.
DIVISION CONTACT NAME CONTACT DETAILS
Trade and IS/Corporate Iain Lewis firstname.lastname@example.org
Supply Sharon Copland-Jones SupplyHRServiceTeam@howdens.com
If you believe that the organisation has 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 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.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.
Some of the organisation's recruitment processes are based solely on automated decision-making. This includes the applicant answering questions based on essential job role criteria, which in turn results in a decision being made as to whether they progress onto the next stage of the recruitment and selection process.
APPENDIX 1 - EXCERPT FROM EMPLOYEE DATA PRIVACY NOTICE
We have identified a number of purposes for collecting and processing your personal data.
These are set out below together with the legal basis we rely on in each case:
A) Recruitment and selection
Considering your suitability to work for us in the role you have applied for, comparing you to other candidates and making recruitment decisions.
This processing is necessary for the compliance with legal obligations to which the Company is subject including the requirement to ensure we do not unlawfully discriminate in our recruitment decision. Some processing is necessary for takings steps at your request to enter into a contract with you. Where you have applied to work for us we need to use your personal data to ensure that are suitable for the role you have applied for and to make an offer of employment to you where appropriate.
Additional processing is necessary for the purpose of the legitimate interests pursued by the Company.
The Company has a legitimate interest in fully assessing applicants to ensure that only suitable and appropriate candidates are selected, to compare candidates and make a fair decision on the most appropriate candidate for the position.
The Company aims to recruit the best person for each vacancy through fair, systematic, effective recruitment and selection procedures. This will contribute towards the Company continuing to meet its business objectives, maintain its reputation and attract high calibre employees.
B) Pre-employment verification and screening
Appropriate pre-employment screening including, where relevant and appropriate, identity check, right to work verification, reference check, credit check, financial sanction check, criminal record checks (if and to the extent permitted by applicable laws), relevant employment history, relevant regulatory status and relevant professional and educational qualifications.
This processing is necessary for the compliance with legal obligations to which the Company is subject including establishment of the right to work in the country in which you are employed.
For specific roles which involve the driving or operation of any vehicle including MHE such as a fork lift truck, Large Goods Vehicle or any other company vehicle the Company will process whether or not you have a valid UK driving licence and all live endorsements on that licence for the purposes of ensuring that the Company is adhering to all required legislation.
Screening which is not legally required is necessary for the purpose of the legitimate interests pursued by the Company.
The Company has a legitimate interest in ensuring that candidates for employment or engagement do not pose an unacceptable risk to the business or its customers and considers the verification carried out necessary to prevent crime and other unlawful acts and to protect the business and customers from fraud, dishonesty or incompetence.
C) Offers of employment and induction
Making job offers, providing contracts of employment or engagement and preparing to commence your employment or engagement where you accept an offer from us.
This processing is necessary for the compliance with legal obligations to which the Company is subject including the requirement to issue written particulars or terms of employment and the requirement not to unlawfully discriminate in the terms of any offer to you.
Additional processing is necessary to take steps to enter into the contract between you and the Company and to perform that contract because we will need information to make an appropriate offer to you and administer your employment contract if you join us.
The remainder of the processing is necessary for the purpose of the legitimate interests pursued by the Company.
The Company has a legitimate interest in ensuring the effective engagement of staff on appropriate terms and conditions of employment and that there is a smooth transition into employment for successful candidates and that information supplied in the recruitment process which is relevant to ongoing employment is maintained. This will contribute towards the Company continuing to meet its business objectives, maintain its reputation and attract high calibre employees.
D) Future job opportunities
To contact you if you are not successful in your initial application should another potentially suitable vacancy arise during the six months following completion of the recruitment process for the role you originally applied for.
This processing is necessary for the purpose of the legitimate interests pursued by the Company.
The Company has a legitimate interest in maintaining an appropriate pool of talent who have shown an interest in working for the Company and who are potentially suitable candidates for employment. This will potentially benefit both initially unsuccessful candidates and the Company. It will contribute towards the Company continuing to meet its business objectives, maintain its reputation and attract high calibre employees.
E) Recruitment feedback and complaints
To deal with any query, challenge or request for feedback received in relation to our recruitment decisions.
This processing is necessary for the compliance with legal obligations to which the Company is subject including ensuring that it is able to demonstrate its compliance with data protection laws and anti-discrimination laws.
Beyond legal compliance, processing is necessary for the purpose of the legitimate interests pursued by the Company.
The Company has a legitimate interest in being able to provide feedback to candidates and to be able to defend any challenge or claim made in connection with our recruitment decision. This will assist the Company to avoid the risk of financial exposure or costs incurred through challenges to recruitment decisions and to maintain its reputation.