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Data Protection Privacy Notice (Recruitment)

What is the purpose of this document?

This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the application process. We are required to notify you of this information, under data protection legislation. Please ensure that you read this notice in conjunction with any other similar notice we may provide to you from time to time when we collect or process personal information about you.

Who collects the information

Clarkson Wright & Jakes, comprising Clarkson Wright & Jakes Ltd and Clarkson Wright & Jakes Services LLP (the Firm) is a ‘data controller’ and gathers and uses certain information about you to enable us to process applications for employment.

Data protection principles

We will comply with the data protection principles when gathering and using personal information, as set out in our CWJ Employee Privacy Notice.

About the information we collect and hold

The table set out in Part A of the schedule below summarises the information we collect and hold up to and including the shortlisting stage of the recruitment process, how and why we do so, how we use it and with whom it may be shared.

The table in Part B of the schedule below summarises the additional information we collect before making a final decision to recruit, ie before making an offer of employment unconditional, how and why we do so, how we use it and with whom it may be shared.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

Where information may be held

Information may be held at our offices and third party agencies, service providers, representatives and agents as described above. 

How long we keep your information?

We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.

We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed.

If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment. For further information, see our CWJ Employee Privacy Notice.

Further details on our approach to information retention and destruction are available in our GDPR Data Audit.

Your right to object to us processing your information

Where our processing of your information is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your information unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

Please contact our Data Protection Partner, Jill Lawton, who can be contacted by email at jill.lawton@cwj.co.uk if you wish to object in this way.

Your rights to correct and access your information and to ask for it to be erased

Please contact Jill Lawton, who can be contacted by email at jill.lawton@cwj.co.uk if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask Jill Lawton for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. Jill Lawton will provide you with further information about the right to be forgotten, if you ask for it.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that our Data Protection Partner can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

The Schedule
About the information we collect and hold

Part A
Up to and including the shortlisting stage

The information we collect

How we collect the information

Why we collect the information

How we use and may share the information

 

Your name and contact details (ie address, home and mobile phone numbers, email address)

From you

Legitimate interest: to carry out a fair recruitment process

Legitimate interest: to progress your application, arrange interviews and inform you of the outcome at all stages

To enable HR to contact you to progress your application, arrange interviews and inform you of the outcome

To inform the relevant manager or department of your application

 

Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests

From you, in the completed application form and interview notes (if relevant)

Legitimate interest: to carry out a fair recruitment process

Legitimate interest: to make an informed decision to shortlist for interview and (if relevant) to recruit

To make an informed recruitment decision

 

 

Details of your referees

 

 

 

 

From your completed application form

Legitimate interest: to carry out a fair recruitment process

In the regulated sector, to comply with our legal obligations to obtain regulatory references

To carry out a fair recruitment process

To comply with legal/regulatory obligations

Information shared with relevant managers, HR personnel and the referee

 

Part B
Before making a final decision to recruit

The information we collect

How we collect the information

Why we collect the information

How we use and may share the information

 

Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, from references obtained about you from previous employers and/or education providers

From your referees (details of whom you will have provided)

Legitimate interest: to make an informed decision to recruit

To comply with our legal obligations

Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice

To obtain the relevant reference about you

To comply with legal/regulatory obligations

Information shared with relevant managers and HR personnel

 

Information regarding your academic and professional qualifications

From you and / or your education provider or relevant professional body

Legitimate interest: to verify the qualifications information provided by you

To make an informed recruitment decision

 

Information regarding your criminal record, in a criminal records certificate (CRC) or enhanced criminal records certificates (ECRC) as appropriate

From you and/or DBS or such other third party provider authorised to perform appropriate checks.

To perform the employment contract

To comply with our legal obligations

Legitimate interest: to verify the criminal records information provided by you

For reasons of substantial public interest (preventing or detecting unlawful acts, suspicion of terrorist financing or money laundering in the regulated sector and protecting the public against dishonesty).

To make an informed recruitment decision

To carry out statutory checks.

Information shared with DBS and other regulatory authorities as required

 

 

Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information

From you and, where necessary, the Home Office

To enter into/perform the employment contract

To comply with our legal obligations

Legitimate interest: to maintain employment records

To carry out obligations and exercise rights in employment law

For reasons of substantial public interest (preventing or detecting unlawful acts)

To carry out right to work checks

Information may be shared with the Home Office

 

A copy of your driving licence or passport

From you

To comply with our legal obligations

To comply with the terms of our insurance

To make an informed recruitment decision

 

Information relating to your health

From you and/or relevant medical professionals authorised to provide such  information on your behalf.

To enter into/perform the employment contract

To comply with our legal obligations

Legitimate interests: to ensure you are fit to perform the duties

 

To make an informed recruitment decision

 

You are required (by law or in order to enter into your contract of employment) to provide the categories of information above to us to enable us to verify your right to work and suitability for the position.

Further details on how we handle sensitive personal information and information relating to criminal convictions and offences are set out in our Criminal Records Information Policy – Employee (available from our HR Department).

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