As part of our recruitment process, the Company will collect and process 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.
What information does the Company collect?
“Personal data” (or personal information), means any information about an individual from which that person can be identified, either just from that information alone, or together with other information we hold.
As part of our recruitment process the Company will collect 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; and
- information to verify your identification and entitlement to work in the UK.
The Company may collect this information in a variety of ways. For example, data might be contained in application forms, CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
If you are offered employment following the recruitment process, we will require further personal data from you, details of which are contained in our Employee Data Privacy Notice.
Personal data may be sourced through information you have posted on job boards or social media sites such as LinkedIn where you have stated that you are currently seeking employment.
The Company may 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, in our HR management systems and on 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. It may also need to process your data to enter into a contract with you.
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 to whom to offer a job. The Company may also need to process data from job applicants to respond to and defend against legal claims.
The Company 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 Company processes such information to carry out its obligations and exercise specific rights in relation to employment.
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.
If your application is unsuccessful, the Company may 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 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 the vacancy and IT staff if access to the data is necessary for the performance of their roles.
We will also share your data with the third parties set out below:
- any member of our group, which means our subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (set out in Appendix A.);
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer; or
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets.
- SOCOTEC – our ISO auditors who ensure we maintain our ISO standards.
We will share your personal data with other entities in our group as part of our regular reporting activities on Company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data in line with our policies. We require these third parties to treat your personal data in accordance with data protection laws law and to keep it confidential. We do 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 Company will not share your data with any other 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. These are in addition to the other organisations as set out in our Employee Privacy Notice.
In addition, should you require any reasonable adjustments to your role it may be necessary to contact an external provider for supporting in understanding your condition and obtaining any specialist equipment. No third party will be contacted without your consent. Third parties may include Occupational Heath, Access to Work etc.
The Company will not transfer your data outside the European Economic Area.
How does the Company protect data?
The Company 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. Further details can be found in the Company’s Information Security Policy, Information Security Coordination, User Access Management policy, and Secure Development Policy.
For how long does the Company keep data?
If your application for employment is unsuccessful, the Company will hold your data on file for 3 months after the end of the relevant recruitment process. If you agree to allow the Company to keep your personal data on file, the Company will hold your data on file for a further 3 months for consideration for future employment opportunities. At the end of that period, or if you withdraw your consent prior to that date, 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.
As a data subject, you have a number of rights. You can:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party.
If you would like to exercise any of these rights, please contact the Compliance team at DPO@thebigword.com.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
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 Company may not be able to process your application properly or at all.
Recruitment processes are not based solely on automated decision-making.