Document Control
OWNER |
Data Protection Officer |
APPROVER |
Director of People |
CLASSIFICATION |
Public Use |
DATE OF ISSUE |
22.03.2023 |
ISSUE |
v2.2 |
REASON FOR ISSUE/UPDATE |
Annual review and update |
LAST REVIEW/UPDATE |
December 2023 |
NEXT REVIEW |
February 2025 |
DISTRIBUTION |
Internal and External |
VERSION |
AUTHOR |
SUMMARY OF CHANGES |
DATE |
1.0 |
Evalian Limited |
First issue (Draft) |
13.02.2023 |
2.0 |
DPO |
First Review – updated owner and approver. Added in contact details for the ICO re complaints. |
27.02.23 |
2.1 |
Director of People |
Final Review and small amends. |
22.03.2023 |
2.2 |
Evalian Limited and DPO |
Annual review and update |
01.02.2024 |
Document Release:
This document remains the property of the Skills for Care Group. Release to regulatory authorities is permitted as required. Release to other organisations or individuals may only be authorised by Company Directors.
Contents
1 Introduction
2 What Personal Data do we process?
3 Purposes and bases for using your Personal Data
4 Sharing your information
5 How long will we retain your information?
6 Your rights
7 Contact
1. Introduction
- Skills for Care Ltd (“SfC”, ”we”, ”us”, ”our”), company number 03866683, of West Gate, 6 Grace Street, Leeds, West Yorkshire, LS1 2RP, are committed to protecting your privacy and meeting our legal obligations when you apply for a job or you (or an agent acting on your behalf) share your employment details with us.
- This privacy notice explains what Personal Data we collect and use relating to employment and contractor candidates (“you”, “your”) during the recruitment process.
- Skills for Care Ltd is the Controller of your Personal Data, registered in the UK with the Information Commissioner’s Office (“ICO”), registration number Z6220820.
- As an information-led business, we place great importance on ensuring the quality, confidentiality, integrity, and availability of the data we hold, and in meeting our data protection obligations where we process Personal Data. We are committed to protecting the security of your Personal Data. We use a variety of technical and organisational measures to help protect your Personal Data from unauthorised access, use or disclosure.
- We update this privacy notice from time to time in response to changes in applicable laws and regulations, to our processing practices and to products and services we offer. When changes are made, we will update the effective date at the bottom of this document.
2. What Personal Data do we process?
2.1. Personal Data means any information about an individual from which that person can be identified, therefore does not include data where the identity of the person has been removed (anonymous data). There are also “special categories” of more sensitive Personal Data which require a higher level of protection. The Controller of the Personal Data we hold about you is Skills for Care Ltd, registered in the UK with the Information Commissioner’s Office (“ICO”), registration number Z6220820.
2.2. When you apply for a position (whether as an employee, worker, consultant, contractor or intern) or submit your CV (or similar employment information) to us, whether directly or through an agency, or attend an interview in person or by remote means, we will collect your Personal Data. This includes:
- Name and contact details (address, mobile phone number and email address);
- Company details (where applicable);
- Date of birth and gender;
- Work history and employment positions held;
- Salary, other compensation, and benefits information;
- Nationality / visa / right to work information (where applicable);
- Academic and professional qualifications, education and skills;
- Photographs you may submit with your application;
- Demographic information;
- Records we create during interviews or correspondence with you;
- Results of pre-employment screening checks (where applicable);
- Images recorded using security CCTV; and
- Any other information you choose to give us.
2.3. We may also collect special category data in accordance with the Equality Act 2010. We will only process special category data where we meet one of the conditions required by law for doing so. This includes complying with legal obligations or exercising specific rights in the field of employment law. We may also ask for your explicit consent to process some special categories of Personal Data.
2.4. We process special categories of Personal Data when we collect or process information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work and to provide appropriate workplace adjustments.
- Purposes and bases for using your Personal Data
We will process your personal information for the following purposes and under the following lawful bases:
Purpose |
Lawful Bases for Processing |
Responding to correspondence from you. |
It is in our legitimate interest to respond to you when you make an employment or general enquiry. |
Processing your application to assess suitability for employment. |
Processing is necessary for taking steps to enter into a contract with you or for the performance of our contract with you. For special category data, the additional basis we rely on relates to our obligations in the field of employment and the safeguarding of your fundamental rights. |
Assessing suitability for employment. |
Processing is necessary for us to comply with our legal obligations. For special category data, the additional basis we rely on relates to our obligations in the field of employment and the safeguarding of your fundamental rights. |
Arranging and conducting recruitment interviews, either in person, via telephone or other means. |
Processing is necessary for taking steps to enter into a contract with you or for the performance of our contract with you. For special category data, the additional basis we rely on relates to our obligations in the field of employment and the safeguarding of your fundamental rights. |
Obtaining necessary references from third parties and conducting pre-employment screening checks, where required. |
Processing is necessary for us to comply with our legal obligations. For special category data, the additional basis that we rely on relates to our obligations in the field of employment and the safeguarding of your fundamental rights. |
Contacting unsuccessful applicants about future suitable vacancies. |
It is our legitimate interest to archive applications, maintain the details of, and stay in contact with, suitable candidates for future roles. |
Sharing Personal Data with third parties including government agencies, law enforcement agencies and others for the purposes or job recruitment or pre-employment check or when required by law. |
It is our legal obligation to cooperate fully as and when required by law. |
4. Sharing your information
4.1. We may share your data with service providers and suppliers to our business who process data on our behalf. In such cases, our service providers and suppliers are Processors and may only use the data in line with our instructions and not for any other purpose. This and other obligations are agreed in the written contract between us and the service providers and suppliers.
4.2. Where we need to transfer or store your Personal Data outside the UK, we will only do so relying on either a UK Adequacy Regulation, the UK International Data Transfer Agreement, or another approved international data transfer mechanism, which contractually oblige third party organisations in those countries to comply with the same data protection standards as legislated within the UK.
4.3. Within SfC, your Personal Data will only be shared with those who need to have access to it, which will primarily be our HR personnel and hiring managers.
5. How long will we retain your information?
5.1. We will retain your Personal Data for only as long as is necessary for the recruitment process. If your candidacy is successful and you are employed or hired by us, your data will be processed and retained as set out in our employee privacy notice, provided to you with your employment paperwork.
5.2. If your candidacy is unsuccessful, we will retain your CV, application details and interview notes for a period not exceeding 12 months.
5.3. We may retain a very limited amount of your Personal Data where it is necessary to comply with our legal obligations or as necessary in relation to legal claims for longer. This is rare but may mean we need to retain your data for 12 months or more.
6. Your rights
6.1. Individuals whose Personal Data we process have the following rights:
- You have the right of access to your Personal Data and can request copies of it and information about our processing of it;
- If the Personal Data we hold about you in incorrect or incomplete, you can ask us to rectify or add to it;
- Where we are using your Personal Data with your consent, you can withdraw your consent at any time;
- Where we are using your personal because it is in our legitimate interests to do so, you can object to us using it this way; and
- In some circumstances, you can restrict our processing of your data, request a machine-readable copy of your Personal Data to transfer to another service provider and compel us to erase your Personal Data.
6.2. If you wish to exercise your rights, please contact us at compliance@skillsforcare.co.uk or write to the address in the ‘Contact’ section, below.
6.3. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). 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.
6.4. In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office if you are concerned about the way in which we are handling your Personal Data.
7. Contact
7.1. You can contact Skills for Care in relation to data protection and this privacy notice by emailing the Data Protection Officer at compliance@skillsforcare.co.uk or by writing to West Gate, 6 Grace Street, Leeds, West Yorkshire, LS1 2RP, marking your letter for the attention of the Data Protection Officer.
Last Updated: 1st February 2024