Data protection privacy notice (recruitment)
This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the recruitment application process. We are required to notify you of this information, under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
Who collects the information
Exemplas Holdings Limited (‘Company’) and its subsidiary companies Exemplas Limited, Exemplas Trade Services Limited, and Enterprise Growth Services Limited (our ‘Group Companies’) are each a ‘data controller’ and gather and use certain information about you. In this notice, references to ‘we’ or ‘us’ mean the Company and Group Companies.
Data protection principles
We will comply with the data protection principles when gathering and using personal information.
About the information we collect and hold
What information
We may collect the following information during the recruitment process up to and including making a final decision to recruit:
- Your name and contact details (i.e. address, home and mobile phone numbers, email address) ☐;
- Details of your academic and professional qualifications, experience and employment history ☐;
- Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs;
- Information regarding your criminal record ☐;
- Details of your referees, one of which will be your most recent employer, or an education provider ☐;
- Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information ☐.
You are required (by law or in order to enter into your contract of employment) to provide the categories of information marked ‘☐’ above to us to enable us to verify your right to work and suitability for the position.
How we collect the information
We may collect this information from you, your referees (details of whom you will have provided), your education provider, the relevant professional body, the Disclosure and Barring Service (DBS) and the Home Office.
Why we collect the information and how we use it
We will typically collect and use this information for the following purposes:
- to take steps to enter into a contract;
- for compliance with a legal obligation (e.g. our obligation to check that you are eligible to work in the United Kingdom);
- for the performance of a task carried out in the public interest; and
- for the purposes of our legitimate interests, but only if these are not overridden by your interests, rights or freedoms.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
How we may share the information
We may also need to share some of the above categories of personal information with other parties, such as HR consultants and professional advisers. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information with our regulators or as required to comply with the law.
Sensitive personal information and criminal records information
Further details on how we handle sensitive personal information and information relating to criminal convictions and offences are set out in our Data Protection Policy, available from our Data Protection Officer (DPO).
Where information may be held
Information may be held at our offices and those of our group companies, and third party agencies, service providers, representatives and agents as described above.
How long we keep your information
We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.
We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised, and the longer period for which they will be kept.
If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment.
Your rights to correct and access your information and to ask for it to be erased
Please contact our Data Protection Officer (DPO) if you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask our DPO for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. The DPO will provide you with further information about the right to be forgotten, if you ask for it.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to contact us
Please contact the Data Protection Officer, if you have any questions about this privacy notice or the information we hold about you by emailing dpo@exemplas.com; or in writing: The Data Protection Officer, Titan Court, 3 Bishops Square, Hatfield, AL10 9NE.
How to complain
We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
Changes to this privacy notice
We may change this privacy notice from time to time. This privacy notice was published on 25 May 2018.