Please read this privacy notice carefully as it explains how we comply with the General Data Protection Regulation (GDPR). The notice was published on 14th December 2018 and may be revised from time to time; we will let you know when this happens.
We are [operating company – including any ‘trading as’]. In order that we can consider and process your application for employment, we need to collect and use information about you (“personal information”). Personal information is anything about you from which you can be identified, but it doesn’t include information from which your identity has been removed (i.e. anonymous data).
As a ‘controller’ of your personal information, we are legally responsible for making sure that your personal information is:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used for any other purpose;
- Relevant to the purposes we have told you about and only used for those purposes;
- Accurate and up to date;
- Kept only as long as we need it for the purposes we have told you about;
- Kept securely.
‘Lawful basis for processing’ your information
The GDPR says that we must have a ‘lawful basis’ for collecting and using your personal information. We rely on the following grounds within the GDPR for this lawful basis:
- Article 6(1)(b) – processing is necessary for the performance of our contracts, both our contract of employment with you and our contracts to provide our services;
- Article 6(1)(c) – processing is necessary for us to demonstrate compliance with our regulatory framework and the law;
- Article 7(1) – you have given consent for us to process your personal information;
- Article 9(2)(h) – processing is necessary for the provision of social care or the management of social care systems and services.
Other lawful grounds for processing your data could apply in certain situations, such as where sharing your personal information is essential in order to protect you from harm (“vital interests”).
The information we collect about you
We need to collect certain information about you in order to process your job application; without this information we cannot consider your application. We may get the information directly from you but also from other sources such as the Job Centre or government work programme or from the people whose names you have given us as referees:
- Your name, sex, contact details and national insurance number;
- Proof that you are legally entitled to work in the UK;
- Details of your education, work history, availability and use of transport for work;
- Details of your skills and qualifications, including any languages spoken;
- The names and contact details of people we can contact for a reference;
- Information about any criminal record you may have;
- Information about your suitability for the job you are applying for, including records of any selection interviews, your answers to selection questions and assessments, and information about any disabilities or health conditions that may require us to make adjustments for you;
- Proof of your identity and details of any names you may have previously been known by;
- Details of any addresses you have previously lived at in the past five years;
- Photographs of your face;
- Information about your age, sex, race or ethnicity, nationality, religion or belief, disability, marital or civil partnership status, sexual orientation and transgender status.
How we use your personal information
We use your personal information to:
- Decide on whether you are suitable for the position for which you have applied;
- Communicate with you about your job application;
- Monitor the effectiveness of our equalities policies in our recruitment processes.
If your application is successful, we will carry forward the information you have provided and give you a further privacy notice explaining what we will do with your personal information once you are employed.
Sharing your personal information
We will not share your information with others unless we have a lawful reason for doing so.
We will share relevant information about your application and about your past employment with the people whose names you have given us as referees.
We will also share your information with certain data processors in order to process your application. For example, our application processing systems are hosted by a separate company. However, the data processors we use can only use your data for the purpose we have asked them to and will not share your data with anyone else or use it to do anything other than allow us to process your application. They must also keep your data safe and secure.
Our company is part of City and County Healthcare Group. Although the group provides its services through a number of different companies, it shares a middle and senior management structure and back-office functions (such as finance and payroll). In order to process your application (and only for that purpose), we may need to share your personal information within the management and back-office structure of City and County Healthcare Group.
We may also share personal information with law enforcement or other authorities if required by law. This includes information required by public bodies to evidence our compliance with the applicable regulatory framework.
We will not share your personal information with any other third party without first asking your permission and will never sell your personal information to anyone.
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 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 long your personal information will be kept
If you choose not to proceed with an application following initial enquiry, we will not keep any pf your personal information.
If you make an application, but it is not successful, or you withdraw it, we will retain a record of your name and national insurance number and information about the progress of your application (such as when you applied, when you were interviewed, whether you passed or failed the assessments, what evidence you provided of identity or your right to work in the UK, whether you attended training, and the reason that your application did not result in employment) for administrative and monitoring purposes only. However, any copies of your personal documents that were taken during your application will be destroyed.
If you do not enter our employment, but you would like us to retain your details so that we can contact you about future employment opportunities, we will give you the option of providing your consent for us to do this (by way of a tick box in the application form).
If your application is successful and you become employed by us, we will retain the personal information you have provided during your period of employment and a further privacy notice will be issued to you.
Under the GDPR, you have a number of important rights. In summary, those include rights to:
- Fair processing of information and transparency over how we use your use personal information;
- Access to your personal information and to certain other supplementary information (which is provided in this privacy notice);
- Require us to correct any mistakes in the information we hold about you;
- Require the erasure (i.e. deletion) of personal information concerning you, in certain situations (although you should be aware that if you ask us to delete any of your personal information that we need in order to comply with our legal or contractual obligations, we may no longer be able to provide you with a service);
- Receive any personal information that you have provided to us in a format that would allow you to pass it on to a third party in certain situations;
- Object at any time to processing of personal information concerning you for direct marketing (although as we have explained, we will not use your data for that purpose);
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
- Object in certain other situations to our continued processing of your personal information;
- Otherwise restrict our processing of your personal information in certain circumstances;
- Claim compensation for damages caused by our breach of any data protection laws.
You will find further information on each of these rights on the Information Commissioner’s website (www.ico.org.uk).
How to contact us
If you wish to exercise any of the above rights or have any other complaints or queries about this notice and our use of your personal information, you can contact us as follows:
Telephone: 020 7186 0500
By post: The Data Protection Officer
City and County Healthcare Group
3rd Floor, Caparo House
101-103 Baker Street
London W1U 6LN
Note that we may ask you to provide proof of your identity before we can discuss your personal information with you.
Your right to complain
If you have a complaint about the way we process your personal information, we would ask you to contact us using the details in the previous section.
We hope that we can resolve any concern you raise, but if you want to do so, you also have the right to complain to a supervisory authority in any European Union (or EEA) state where you work or live. In the UK, the supervisory authority is the Information Commissioner, who may be contacted at www.ico.org.uk/concerns/ or by telephone on 0303 123 1113.
Do you need extra help?
If you would like this notice in another format (e.g. audio, large print or braille), please contact us (see ‘How to contact us’ above).