What is the
purpose of this document?
The PSA is a "data controller". This means that we are
responsible for deciding how we hold and use personal information about you.
You are being sent a copy of this privacy notice because you are applying for
work with us (whether as an employee, worker or contractor). It makes you aware
of how and why your personal data will be used, namely for the purposes of the
recruitment exercise, and how long it will usually be retained for. It provides
you with certain information that must be provided under the UK General Data
Protection Regulation (GDPR).
Data
protection principles
The GDPR sets out principles with which data controllers and
processors must comply when processing personal data (Article 5). These
principles form the core of the obligations of the data controller and will
usually form the basis of any claim that a data controller has not complied
with its statutory duties.
We will comply with data protection law and principles, which
means that your personal data will be:
·
Used lawfully, fairly and in a transparent way.
· Collected only for valid purposes that we have clearly explained
to you and not used in any way that is incompatible with those purposes.
·
Relevant to the purposes we have told you about and limited only
to those purposes.
·
Accurate and kept up to date.
·
Kept only as long as necessary for the purposes we have told you
about.
·
Kept securely.
The kind of
information we hold about you
The GDPR defines personal data as "any information relating
to a data subject" (Article 4(1)). A data subject is the identified or
identifiable person to whom the personal data relates and, in relation to this
document, is the employee, worker or contractor applying for work.
In connection with your application for work with us, we will
collect, store, and use the following categories of personal information about
you:
·
The information you have provided to us in your curriculum vitae
and any covering letter.
·
The information you have provided on our application form,
including name, title, address, telephone number, personal email address, date
of birth, gender, employment history, qualifications.
·
Any information you provide to us during an interview.
·
The results of any tests you have undertaken as part of your
application or interview process.
We may also collect, store and use the following "special
categories" of more sensitive personal information:
·
Information about your race or ethnicity, religious beliefs,
sexual orientation and political opinions.
·
Information about your health, including any medical condition,
health and sickness records.
·
Information about criminal convictions and offences.
How is your
personal information collected?
We collect personal information about candidates from the
following sources:
·
You, the candidate.
·
Any recruitment agency who has submitted an application to us on
your behalf, from which we collect the following categories of data: The
information you have provided to us in your curriculum vitae and any covering
letter.
·
The information you have provided on our application form,
including name, title, address, telephone number, personal email address, date
of birth, gender, employment history, qualifications.
Your named referees, from whom we collect the following
categories of data: your period of employment, job title, reasons for leaving,
salary on leaving, number of sick days and comments upon your attendance and
timekeeping, working relationships and conduct at work.
How we will
use information about you
We will use the personal information we collect about you to:
·
Assess your skills, qualifications, and suitability for the
role.
·
Carry out reference checks, where applicable.
·
Communicate with you about the recruitment process.
·
Keep records related to our recruitment processes.
·
Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint
you to the role since it would be beneficial to our business to appoint someone
to that role.
We also need to process your personal information to decide
whether to enter into a contract of employment with you.
Having received your CV and covering letter and/or your
application form, we will then process that information to decide whether you
meet the basic requirements to be shortlisted for the role. If you do, we will
decide whether your application is strong enough to invite you for an
interview. If we decide to call you for an interview, we will use the
information you provide to us at the interview to decide whether or not to
progress you to the second interview stage OR offer you the role. If we decide
to offer you the role, we will then take up references before confirming your
appointment.
If you fail
to provide personal information
If you fail to provide information when requested, which is
necessary for us to consider your application (such as evidence of
qualifications or work history), we will not be able to process your
application successfully. For example, if we require references for this role
and you fail to provide us with relevant details, we will not be able to take
your application further.
How we use
particularly sensitive personal information
Particularly sensitive personal data is personal data that
reveals:
·
Racial or ethnic origin.
·
Political opinions.
·
Religious and philosophical beliefs.
·
Trade union membership.
·
Genetic data.
·
Biometric data.
·
Health data.
·
Sex life and sexual orientation.
We will use your particularly sensitive personal information,
with your explicit consent, in the following ways:
We will use information about your disability status to consider
whether we need to provide appropriate adjustments during the recruitment
process, for example whether adjustments need to be made during a test or
interview .
We will use information about your race or national or ethnic
origin, religious, philosophical or moral beliefs, or your sexual life or
sexual orientation, to ensure meaningful equal opportunity monitoring and
reporting.
Where
appropriate, we will collect information about criminal convictions as part of
the recruitment process or we may be notified of such information directly by
you in the course of you working for us.
Automated
decision-making
You will not be subject to decisions that will have a
significant impact on you based solely on automated decision-making.
Data security
We have put in place appropriate security measures to prevent
your personal information from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access to your
personal information to those employees, agents, contractors and other third
parties who have a business need-to-know. They will only process your personal
information on our instructions and they are subject to a duty of
confidentiality. Details of these measures may be obtained from our Data
Protection Officer (details provided below).
We have put in place procedures to deal with any suspected data
security breach and will notify you and the ICO of a suspected breach where we
are legally required to do so.
Data sharing
We may have to share your data
with third parties, including third-party service providers.
We require third parties to
respect the security of your data and to treat it in accordance with the law.
We may transfer the personal
information we collect about you outside the EU. We will only do this
where we are satisfied that the country to which we transfer your data is
deemed to provide an adequate level of protection for your personal
information.
To ensure that your personal
information does receive an adequate level of protection we have put in place
appropriate measures to ensure that your personal information is treated by
those third parties in a way that is consistent with and which respects the EU
and UK laws on data protection.
We will share your personal information
with third parties where required by law, where it is necessary to administer
the recruitment process with you or where we have another legitimate interest
in doing so.
”Third parties” includes
third-party service providers (including contractors and designated agents).
The following activities are carried out by third-party service providers: IT
services, recruitment agencies, and HR consultants. For building access and
security Ofcom, we will share necessary information with Ofcom.
All our third-party service
providers are required to take appropriate security measures to protect your
personal information in line with our policies. 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.
Data
retention
We will retain your personal information for the following
periods:
For roles involving a 1
stage interview process:
-
12 months from date of receiving the application for those
candidates not selected for interview;
-
12 months from the date the position is filled for those who
were selected for interview
For roles involving a 2
stage interview process:
-
12 months from the date of receiving the application for those
who were not selected for interview or who were not selected for second
interview;
-
12 months from the date the position is filled for those who
were selected for second interview
We retain your personal information for the above periods so
that we can show, in the event of a legal claim, that we have not discriminated
against candidates on prohibited grounds and that we have conducted the
recruitment exercise in a fair and transparent way. Where your personal data is
kept for 12 months from the date the position is filled, this is so we can
contact you as a credible candidate should the role become re-available and to
potentially recruit you to the role without the need to re-initiate the interview
process. Candidates are automatically contacted after a year to confirm their
details will be deleted. The candidate
can choose to request for their
account and some personal
details to be retained.
We will securely destroy your personal information in accordance
with our data retention policy.
If we wish to retain your personal information on file on the
basis that an opportunity may arise in future and we may wish to consider you
for that, we will write to you separately, seeking your explicit consent to
retain your personal information for a fixed period on that basis.
Rights of
access, rectification, erasure, and restriction
Your rights
in connection with personal information
Under certain circumstances, by law you have the right to:
·
Request access to your personal information (commonly known as a
"data subject access request"). This enables you to receive a copy of
the personal information we hold about you and to check that we are lawfully
processing it.
·
Request correction of the personal information 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 information. This enables you
to ask us to delete or remove personal information 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 information where you have exercised your right
to object to processing (see below).
·
Object to processing of your personal information where we are
relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to object to
processing on this ground. You also have the right to object where we are
processing your personal information for direct marketing purposes.
·
Request the restriction of processing of your personal
information. This enables you to ask us to suspend the processing of personal
information about you, for example if you want us to establish its accuracy or
the reason for processing it.
·
Request the transfer of your personal information to another
party.
If you want to review, verify, correct or request erasure of
your personal information, object to the processing of your personal data, or
request that we transfer a copy of your personal information to another party,
please contact our Data Protection Officer in writing.
Right to
withdraw consent
W
here we have obtained your consent to the
collection, processing and transfer of your more sensitive personal information
for a specific purpose
you have the right to withdraw your consent for processing for
that purpose at any time. To withdraw your consent, please contact the DPO.
Once we have received notification that you have withdrawn your consent, we
will no longer process your information for that purpose unless we have another
legitimate basis for doing so in law.
Data
protection officer (DPO) and the Information Commissioner’s Office (ICO)
We have appointed a data protection officer (DPO) to oversee
compliance with this privacy notice. If you have any questions about this
privacy notice or how we handle your personal information, please contact the
DPO. The DPO can be reached at dpo@psauthority.org.uk.
You have the right to
make a complaint at any time to the Information Commissioner's Office (ICO),
the UK supervisory authority for data protection issues.
This policy will be reviewed quarterly.