Job applicant privacy notice
Purpose
This notice is designed to clarify and provide guidance on the type of data collected by the company during the job application process and how it is processed.
A summary of areas covered by this policy is detailed below. Should you have any questions in relation to this document, please speak to the HR manager:
- General principles
- What information does the company collect?
- Why does the company processes personal data?
- Who has access to the collected data?
- How does the company protect data?
- How long does the company keep data?
- Your rights
- What if you do not provide personal data?
Data controller: Priority Freight, 6-7 Menzies Road, Whitfield, Kent CT16 2HQ
Data protection lead: Group Compliance Manager | privacyrights@priorityfreight.com
GENERAL PRINCIPLES
As part of any recruitment process, the company collects and processes personal data relating to job applicants.
The company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
Recruitment processes are not based solely on automated decision-making.
WHAT INFORMATION DOES THE COMPANY COLLECT?
The company collects and processes a range of information about you. This includes:
- 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 company needs to make reasonable adjustments during the recruitment process
- Information about your entitlement to work in the UK
- Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief
The company collects this information in a variety of ways. For example, data is collected through application forms and CVs; from your passport or other identity documents such as your driving licence; or collected through interviews or other forms of assessment.
The company 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 company 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, on HR management systems and other IT systems (including email).
WHY DOES THE COMPANY PROCESS PERSONAL DATA?
The company needs to process data to take steps, at your request, prior to entering into a contract with you. The company also needs to process your data to provide you with an employment contract.
In some cases, the company 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 company 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 company to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide 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 company 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 company 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 company processes other special categories of data, such as information about ethnic origin, sexual orientation, health, religion or belief, age, gender or marital status, this is done for the purposes of equal opportunities monitoring with the explicit consent of job applicants, which can be withdrawn at any time.
For some roles, the company is obliged to seek information about criminal convictions and offences. Where the company 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.
The company will not use your data for any purpose other than the recruitment exercise for which you have applied.
If your application is unsuccessful, the company will keep your personal data on file in case there are future employment opportunities for which you may be suited. The company 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 company will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment.
The company 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.
Your data may be transferred outside the European Economic Area (EEA) for business contact purposes, such as your business address and telephone number. Data is transferred outside the EEA on the basis of binding corporate rules.
HOW DOES THE COMPANY PROTECT DATA?
The company takes the security of your personal 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.
HOW LONG DOES THE COMPANY KEEP DATA?
If your application for employment is unsuccessful, the company will hold your data on file for six months after the end of the relevant recruitment process. If you agree to allow the organisation to keep your personal data on file, the company will hold your data on file for a further six months for consideration in 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. The periods for which your data will be held will be provided to you in a new 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 company to change incorrect or incomplete data
- Require the company 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 company is relying on its legitimate interests as the legal ground for processing
- Ask the company to stop processing data for a period, if data is inaccurate or there is a dispute about whether or not your interests override the company’s legitimate grounds for processing data
If you would like to exercise any of these rights, please contact us at: privacyrights@priorityfreight.com.
You can make a subject access request by completing the company’s subject access request form.
If you believe that the company 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 company 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.
FURTHER INFORMATION
The company will review policies and procedures periodically to reflect changes in legislation, good practice, etc.
Issue date: September 2023
