Fair Processing Notice (Job applicant data)
During the course of recruitment we will process personal data (which may be held on paper, electronically, or otherwise) about our job applicants and we recognise the need to treat it in an appropriate and lawful manner, in accordance with the General Data Protection Regulations (GDPR). The purpose of this notice is to make you aware of the types of data that we hold on job applicants. It also sets out how we collect data, why we process that data and how long we keep it for along with other relevant information.
This notice applies to all job and volunteer applicants.
PFH is deemed a data controller, meaning that we determine the purpose and processes to be used when using personal data.
We will comply with the six data principles outlined in the GDPR, which say that personal data must be:
We hold many types of data throughout the recruitment and selection process, including:-
We collect data in a variety of ways including the information normally included in a CV or cover letter, or notes made during the selection process. Further information will be collected after an offer is made to the preferred candidate satisfying pre-employment checks and then on commencement of employment for the successful candidate only.
We may collect data from third parties, such as employment agencies/former employers when gathering references and the Disclosure and Barring Service.
Personal data is kept in vacancy files or within the Company’s HR and IT systems or third party recruitment platforms.
We will only process personal data for certain reasons as defined by GDPR:
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 for example making reasonable adjustments for disabled candidates/employees is a legal requirement.
“Special categories of personal data” about race; ethnic origin; politics; religion; trade union membership; genetics; biometrics; health; sex life; or sexual orientation will be processed in accordance with more stringent guidelines. Usually this will mean that you have given your explicit consent, or that the processing is required in order for us to carry out our legal obligations, is of substantial public interest, or you have already made the data public.
We may process special categories of personal data relating to job applicants including, as appropriate: For the purpose of equal opportunities monitoring due to our position as a public service provider
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations, exercise specific rights under employment law or to perform a task in the public interest.
We will collect criminal conviction data (where it is appropriate) given the nature of the vacancy and where the law permits us. This data will usually be collected only for the preferred candidate via the Disclosure and Barring Service. We process this data because of our legal obligation to safeguard residents classed as vulnerable adults.
If you are unsuccessful in obtaining employment, your data will not be used for any reason other than in the ways explained in relation to the specific application you have made.
One of the reasons for processing candidate 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 your application/offer of employment if you fail to do so e.g. confirming right to work in the UK or, where appropriate, confirming legal status for carrying out work via a criminal records check (DBS).
Data will be shared with colleagues within PFH where it is necessary for them to undertake their duties with regards to recruitment. This includes, for example, the HR department, those included on the shortlisting and selection panels and the IT department if you require access to our systems to undertake any assessments requiring IT equipment.
In some cases, we will collect data from third parties such as employment agencies and use recruitment platforms such as Indeed to obtain your personal data.
We do not share your data with bodies outside of the European Economic Area.
We will ensure that appropriate measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. We have in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction.
Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data.
In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of the recruitment exercise in the case of equal opportunity data. All other information gathered during the recruitment and selection process will be retained for one year as outlined in Appendix 1.
Data will be destroyed or erased from our systems after this period.
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.
You have the right to:
Where we are relying solely on your consent to use 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 consider that the data protection principles have not been followed in respect of personal data about yourself or others you should raise the matter with our Data Protection Officer, Racheal Hoult. Any breach of the GDPR will be taken seriously.
The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO) and complaints can be made direct to them.
Part 1 Recruitment and Selection
Applications and interview notes
(for unsuccessful candidates)
|Equal Opportunity Forms including Gender, Marital Status, Age, Ethnic Origin, Disability, Sexual Orientation, Religious Belief/Faith, Criminal Conviction||Duration of recruitment campaign (1 month)||