Privacy Notice for Job Applicants
As part of any recruitment process, the Carey Group, as a ‘data controller’ collects and processes personal data relating to job applicants. The Carey Group is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations in accordance with the General Data Protection Regulations (GDPR).
It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the GDPR.
What information does the Carey Group collect?
The Carey Group collects, processes and stores the following categories of information about you. This includes:
- your name, address and contact details, including email address and telephone number, date of birth and gender
- Recruitment selection or development surveys/questionnaires, CV and references.
- Driving licence details and where applicable, penalty points and/or disqualifications.
- the terms and conditions of your employment;
- details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with the Carey Group;
- information about your remuneration, including entitlement to benefits such as pensions or insurance cover and other flexible benefits as appropriate;
- information about your nationality and entitlement to work in the UK;
- information about medical or health conditions, including whether or not you have a disability for which the Carey Group needs to make reasonable adjustments;
- trade union membership; and
The Carey Group may collect 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/ assessments/surveys.
The Carey Group may also collect personal data about you from third parties, such as employment agencies, references supplied by former employers, information from employment background check providers and information from criminal records checks. The Carey Group 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 the Carey Group’s email system).
Why does the Carey Group process personal data?
The Carey Group needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.
In some cases, the Carey Group 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 Carey Group 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 us Carey Group to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
The Carey Group may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. The Carey Group processes such information to carry out its obligations and exercise specific rights in relation to employment.
For some roles, we are obliged to seek information about criminal convictions and offences. Where we seek this information, it does so because it is necessary for us to carry out its obligations and exercise specific rights in relation to employment.
If your application is unsuccessful, the Carey Group may keep your personal data on file in case there are future employment opportunities for which you may be suited. The Carey Group 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 may 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 Carey Group will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. We 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 where required.
All third-party service providers and other entities in the Group are required to take appropriate security measures to protect your personal information in line with our policies. We will not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
The Carey Group will not transfer your data outside the European Economic Area.
How does the Carey Group protect data?
The Carey Group takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
In addition, we will limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. Where the Carey Group engages third parties to process personal data on its behalf, they do so based on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and Group measures to ensure the security of data. Details of these measures can be found in our GDPR Policy.
For how long does the Carey Group keep data?
If your application for employment is unsuccessful, the Carey Group will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow the Carey Group to keep your personal data on file, the Carey Groups will hold your data on file for a further 12 months 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 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. Details regarding the periods for which your data will then be held will be provided to you in a new privacy notice.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require the Carey Group to change incorrect or incomplete data;
- require the Carey Group 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 Carey Group is relying on its legitimate interests as the legal ground for processing;
- request that the Carey Group suspend processes of your data for example, if you want us to establish its accuracy or the reason for it processing it; or
- request that we transfer your personal information to another party.
If you would like to exercise any of these rights, please contact HR.firstname.lastname@example.org.
If you believe that the Carey Group 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 Carey Group during the recruitment process. However, if you do not provide the information, the Carey Group may not be able to process your application properly or at all.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention, and this type of processing is only permissible in specified circumstances.
Recruitment processes at the Carey Group are not based solely on automated decision-making.
If you have any questions at all about this privacy notice, please contact HR.email@example.com.