GDPR Candidate Privacy Notice
Version 1.0, November 2018
The “data controller” for the purposes of this GDPR Candidate Privacy Notice is www.e-cargobikes.com Ltd. As the data controller, we are responsible for deciding how we hold and use personal data (information that identifies a person) about you. This privacy notice is applicable to you because you are applying to 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 process, and how long we will retain that data. It provides you with the information that we are required to give you under the General Data Protection Regulation ((EU) 2016/679).
Our HR Manager will oversee compliance of this candidate privacy notice. If you have any questions regarding the content, please contact them at email@example.com
What Personal Data is Collected
- The information in your curriculum vitae and/or covering letter and/or any other document uploaded by you.
- · Any information provided to us during an interview or assessment.
· Any information provided to us in other forms, including but not limited to an application form which we may ask you to complete.
- We may also collect, store and use the following “special categories” of more sensitive personal data about you:
- Information about your health, including any medical condition or disability.
- Information about any criminal convictions and offences.
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
We collect personal data about you throughout the application and recruitment process. This data will be received through:
- Recruitment agencies (from which we may collect: curriculum vitae, and/or covering letter and/or any other documents uploaded).
- Your named referees (from which we collect: name, company name, email address and telephone number, personal reference/or professional reference, start and end dates of employment, last job title and reason for leaving).
- Data which is from a publicly accessible source, e.g. LinkedIn, Facebook.
If you fail to provide information when requested which we consider necessary for us to consider your application (such as evidence of qualifications or work history to assess your suitability for the role), we will not be able to process your application.
Purposes of Processing Personal Data
We will use the personal data we collect about you to assess your skills, qualifications and suitability for the role or future roles, carry out background and reference checks if applicable, communicate with you about the recruitment process, keep records related to our hiring processes and comply with our legal or regulatory obligations. It is in our legitimate interests to assess and consider whether to appoint you to the role or other future roles since it is beneficial to our business to fill such vacancies with suitable candidates.
We may also need to process your personal data to decide whether to enter into a contract of employment with you.
We will use your special category personal data in the following ways:
- We will use information about any 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, interview or other meeting.
- We may 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.
We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role and we may collect and hold information about any criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory).
Data Sharing and Security
Your personal data will be shared internally, including with relevant departments, such as hiring manager and relevant staff on the selection team when hiring, if such sharing is necessary for them to perform their duties.
We have put in place appropriate security measures, internal policies and controls, to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those staff who have a business need to access such personal data. Such parties will only process your personal data on our instructions and they will be subject to a duty of confidentiality.
If your application is successful we will retain your personal data pursuant to our privacy notice for employees, workers and contractors. If you are unsuccessful we will retain your personal data for a period of 24 months after we have communicated to you our decision. We retain your personal data for that period so that we can show that, for example, in the event of a legal claim, we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way or in order to consider you for any future roles that may become available. After this period, we will securely destroy your personal data in accordance with our applicable data retention policy, applicable laws and regulations.
Your Rights as a Data Subject
As a ‘Data Subject’, you have a number of rights in certain situations to:
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data.
- Object to the processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to us processing on this basis.
- Request the restriction of processing of your personal data. You have the right 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 us processing it.
- Request access to your personal data (commonly known as a “data subject access request”).
- Request the transfer of your personal data to another party.
- Make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact the HR Manager via email to firstname.lastname@example.org or in writing to HR Manager, Unit 15, 149 Roman Way, London N7 8XH.
Your Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for the avoidance of doubt we are not seeking, and you are not giving any consent under this notice), you have the right to withdraw your consent for that specific processing at any time. To withdraw any such consent, please contact the HR Manager.