British Gymnastics Privacy Notice – Recruitment
This Privacy Notice takes effect on 25 May 2018.

Your privacy is extremely important to British Gymnastics and we are fully committed to providing you with clear and transparent information about how we use your personal information. We value the trust you give us when sharing your personal information. We will ensure robust measures are in place to keep your information secure and will only use it for the purposes outlined in this policy.

British Gymnastics is the data controller of your personal data. This notice explains what personal information we collect and how we use it as part of the recruitment process. If you are recruited, information about how we use your information during your employment and after it ends is provided in our Employment Privacy Notice. We are required to provide this information under data protection law.

You can contact our Data Protection Officer (DPO) at
data.protection@british-gymnastics.org or Lilleshall NSC, Newport, Shropshire, TF10 9NB if you have any questions.

About us
British Gymnastics (BG) is a not-for-profit membership organisation and is the central body that governs the sport of gymnastics across the UK. We have a wholly BG-owned subsidiary company, namely Gymnastics Enterprises Limited (GEL) that provides BG merchandise, awards and resources and ticketing for some BG events and we also support The British Gymnastics Foundation (BGF); a registered charity that provides grants and supports community gymnastics and activity. British Gymnastics is the employer for individual who work in GEL or the BGF so this notice is applicable to GEL or BGF employees and workers and BGF non-executive directors.

Our employee privacy notice explains:

• What information we collect about you
• How we use your information for contractual purposes or to comply with legal obligations
• How we use information about you for legitimate purposes
• Other lawful reasons for using information about you
• Why we share information about you
• How long we keep information about you
• Transfers of data out of the European Economic Area (EEA)
• Your rights in respect of your personal information
• Changes to our privacy notice
• How to contact us

What information we collect about you
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t. We collect the following personal information:

Contact details (address, home and mobile phone numbers, email address);
Details of your experience and employment history (including job titles, salary and working hours) and interests (in some cases, this may be provided by a recruitment agency to which you have subscribed);
Academic and professional qualifications;
Nationality and immigration status and information from related documents, such as your passport or other identification and immigration information and other relevant documents that demonstrate right to work in UK;
Information about any relevant disabilities;
Equality profile information (age, sex, disability, race/ethnicity, sexual orientation, religious or similar beliefs and gender reassignment);
Details of your referees and any references provided;
Details relating to criminal record checks (disclosure number and date of the check) and any criminal convictions, cautions or official information and warnings and other relevant additional information e.g. information from probation services;
Notes taken by recruitment panel members and results of assessment tests conducted at interview.

We collect most of this information using our online application system, which is provided on our behalf by Cascade.

How we use your information and associated legal reasons
Exactly how we use your personal data will depend on whether you an external contractor or you are British Gymnastics member who is contracted to provided services to British Gymnastics. We process your personal data with the view to entering into a contract with you and to comply with associated legal obligations.

If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete these checks before employment can commence. We have a legal obligation to confirm your identity and that you have a right to work in the United Kingdom and to seek references to verify your trustworthiness, integrity and reliability.

For certain positions, we have a legal obligation to carry out criminal records checks to ensure that you are suitable to undertake the role in question. The Safeguarding Vulnerable Groups Act 2006 or Safeguarding Vulnerable Groups (Northern Ireland) Order 2007 provides the legal framework for preventing people who are deemed unsuitable to work with children and/or adults at risk from gaining access to them through their work or voluntary activities. The Act, amended by the Protection of Freedoms Act 2012, provides the legal definition of regulated activity with children and adults (i.e. work that a person who has been barred must not do). Our Use of Criminal Records Checks Policy (click here for the policy) outlines the specific roles where a check is required as a condition of membership.

In England and Wales criminal record checks and barring decisions are the responsibility of the Disclosure and Barring Service (DBS). These services are provided by Access NI in Northern Ireland.

Click here for the DBS Privacy notice
Click here for the Access NI Privacy notice.

When you apply for a criminal record check, it is necessary to verify your identity. This verification is usually carried out by a designated club official. Access NI requires us to retain copies of your ID documents e.g. your passport, birth certificate, driving licence, utility bill etc. for 90 days after the date of issue of the certificate. After this period, these copies are securely destroyed. The DBS does not require copies of ID documents to be retained. British Gymnastics provides a paper-based application service but contracts the services of GBG to provide an electronic DBS service on our behalf.

We will receive confirmation that the check is clear and will be provided with the disclosure number and date of issue. If the disclosure is not clear, we will ask you to provide a copy of your disclosure certificate and we will assess the risk that you may pose to others and whether we can implement controls to minimise any risk. This can require us to contact other agencies to obtain further information such as probation services, which we will only do so with your consent. You will be consulted as part of any assessment. Any criminal records information and other information obtained in connection with an assessment of the disclosed content will be deleted within six months of the date of the check unless the assessment and decision has not been concluded in this time period.

Special categories of personal data
Special categories or personal data are data that is more sensitive and includes health and medical information and some information relating to your equality profile such as information about your sexual orientation, race, disabilities, religion and beliefs and gender reassignment.

We ask you to provide information about any relevant disabilities and medical conditions as we have a legal obligation under the Equality Act 2010 to make any reasonable adjustment for individuals with disabilities who need this to be able to participate in the recruitment and selection process.

Where we process special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring to help as assess whether we are an inclusive employer and to ensure we comply with responsibilities under the Equality Act 2010. We understand that not everyone is comfortable to provide this information so this information is not mandatory. You have a choice to select ‘prefer not to say’ in response to each monitoring question and it will not affect your application if you do not wish to answer. This information allows us monitor whether our employment practices are fair and to obtain statistical information as required to inform equality impact assessments.  We will never be made available to anyone involved in shortlisting or making recruitment decisions and it will never be used in a way which could identify you.

In other cases, we have a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows the organisation to:

• Maintaining recruitment records to demonstrate our compliance with legal and regulatory and obligations and good employment practice.
• Undertaking background vetting and taking up references from previous employers. 
• Maintaining and promoting equality and inclusion in our recruitment practices
• Monitoring and managing access to our systems and facilities and protecting our networks, and personal data against unauthorised access, modification or data breaches.

Other lawful reasons for using information about you
We may need to process information about you to comply with a legal or statutory obligation. This includes but is not limited to:

• Business management and planning, including accounting and auditing, compliance and conducting our normal business operations to managing our relationship with you.
• To maintain records of amendments to consents and to create suppression lists to ensure people who object to processing are excluded from the relevant processing activity.

Where the information we are processing is a special category of data, in addition to processing this information to comply with employment or social security or social protection law we may process this type of information if one of the following applies:

• We have your explicit consent or you have made the information public;
• It is in your vital interests and you are unable to provide consent e.g. if you are unconscious and unable to consent;
• We are required to do so to establish, exercise or defend a legal claim;
• There is a substantial public interest in doing so.

Why we share information about you
We may need to share limited personal information with the following third party organisations:

• Statutory/regulatory authorities and other organisations
On occasion, it may be necessary to share information with bodies such as the Health & Safety Executive (HSE), Information Commissioner’s Office (ICO), Disclosure and Barring Service (DBS) or Access NI.
• Professional and legal advisors including our insurers
• Funding Agencies e.g. UK Sport, Sport England and Sport NI
We will need to share information with our funding partners in line with the conditions of funding. This information will usually be anonymised unless they are part of the recruitment panel.
• External service providers who are contracted to provide specific services on our behalf
Our HR Management system where much of the information about you is stored is provided by Cascade. We use the services of other third-party providers to help us in areas such as:
• IT and cloud storage e.g. Microsoft 365
• Criminal records checks, which are provided on our behalf by GBG.

We will limit any of your personal data that we share with third party providers to the minimum required to provide the service and the provider will only be able to use personal data for the specific purposes for which it was shared and must deleted or return any information to us once the service has been provided.

How long we keep information about you
We will only keep your personal information for any no longer than is necessary for the recruitment and selection purposes.

If you are successful, the information you provide during the application process will generally be retained by us as part of your employee record for the duration of your employment plus 6 years following the end of your employment. If you are unsuccessful at any stage of the process, the information you have provided will be retained for 6 months taking account of limitation periods for potential claims such as discrimination. After this period, and subject to the conclusion of any legal claims, your records will be destroyed securely unless there is a clear business reason for keeping these records for longer. Should this situation arise, we will only retain the records with your consent, which you can withdraw at any time.

Please contact the DPO if you require any further information on specific retention periods.

Transfers of data out of the EEA
We may transfer your personal information to third-party data processors who are based in the countries outside the European Economic Area (EEA). We use some US-based companies that provide services such as IT services. We only use US-based organisations that are self-certified as adhering to the EU-US Privacy Shield.

We will not transfer your information to any processors based in other countries outside the EEA unless there is a European Commission adequacy decision for the specific country to which the data is transferred or where we can be certain that there are adequate safeguards provided for your information and individual rights standards that meet the requirements of data protection law. Please contact our DPO if you require any further information relating to international transfers.

Your rights in respect of your personal information
You have important rights under data protection law. In summary these include:
• To be informed about how your information is processed
We hope that the information in our privacy notice has achieved this but please contact our Data Protection Officer (DPO) if there is any additional information you require.

• To access any personal data held about you
You have the right to see the personal information we hold about you. This is called a Data Subject Access Request. You can log into your Cascade online recruitment account and view the details you have provided and can also request a copy of any other personal information that we hold by writing to our DPO.

If we do hold information about you, we will:

- Describe the information we hold and tell you why we are holding it;
- Tell you who it could be shared with; and
- Provide you with a copy of the requested information in an easy to understand format.

Alternatively, if you request is straight forward, you can just ask HR for with the information you require and if appropriate, we will try to deal with this informally.

• To have your data rectified if it is inaccurate
Prior to submitting your application, you can log into you Cascade Online account and amend any information in responses to the questions. You can also amend your response to the equality profile questions at any time. You can ask us to correct or amend any inaccurate or incomplete information by contacting us in writing at the address below. We will either make the requested amendments or provide an explanation as to why we are not making changes.

• To have your data deleted (except if there is a valid lawful reason to retain it)
You have a right to request the deletion of your information in advance of the above retention periods. We will delete this information unless there is a lawful reason for the information to be retained. 

Where you have given us your consent for your personal information to be used for a particular purpose, you have the right to withdraw this consent at any time, which you may do by contacting HR or the DPO using the contact details below. Your withdrawal of consent will not affect any use of the data that was made before you withdrew your consent.

• To have your information restricted or blocked from processing
If you object to processing, we will restrict the processing of your information for the purpose to which you are objecting whilst we review your objection.

• To portability
This means that you request that the information you have provided is moved or transferred to any alternative provider.

• To object to:
- Any processing based on legitimate interests
- Any automated decision making including profiling
- Your personal information being used for direct marketing activities

Click her to learn more about your rights

To exercise any of these rights or if you have any questions about our website privacy notice please contact our DPO on the contact details provided below.

While we hope to be able to resolve any concerns you have about the way that we are processing your personal data, you have the right to lodge a complaint with the Information Commissioners Office (ICO) if you believe your data has been processed in a way that does not comply with the GDPR or have any wider concerns about our compliance with data protection law. You can do so by calling the ICO helpline on 0303 123 1113 or via their website.

Changes to our privacy notices
We keep our privacy notices under regular review. This notice was last updated on 24th May 2018.

How to contact us
We hope that you have found this information helpful but if you have any questions or concerns, please contact our Data Protection Officer (DPO) who will be pleased to help you.
Data Protection Officer
British Gymnastics
Lilleshall NSC
Nr Newport
Shropshire
TF10 9NB

Data.protection@british-gymnastics.org

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