The Candidate Privacy Notice
Overview
During any recruitment process, we collect and process personal data relating to individuals who make job applications with THE and TKP or any associated companies, therefore for the purpose of this notice the use of
“THE”, “we”, “us” or “our” shall mean all parties, collectively and individually, whether acting as controller or processor.
We are committed to complying with data protection obligations and this privacy notice explains what personal data we will hold about you, how it is collected and what we may make of that data during the recruitment process. This notice is non-contractual and as such we may update it at any time.
Who is the Data Controller
If you are applying for a role with THE or TKP, then WUI is the controller of your personal data. We respect your data, and your privacy is important to us.
This notice explains how WUI processes your personal data and describes your data protection rights, including a right to object to some of the processing which THE carries out.
More information about your rights, and how to exercise them is set out in the “your rights” section.
If you have any queries about data protection or your rights under this notice, please contact our HR team.
What information do we collect?
We may collect a range of information about you, and this may be either personal data or special category data which is more sensitive that ordinary personal data. The data we may collect includes:
• Your name, title, address and contact details, including email addresses and telephone number
• Biometric data such as photographs, including those on passports and driving licences
• Details of your education, qualifications, skills, experience, and employment history, including start and end dates, with previous employers as well as any references taken up during the recruitment process
• Assessment results if applicable
• Your preferences for location, type, and hours of work with us
• Information about your current level of salary, including entitlement to any benefits connected to your employment
• Your nationality and entitlement to work in the relevant country
• Details about medical or health conditions, including whether you have a disability for which we need to make reasonable adjustments during the recruitment process
• Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
We may also collect this information in a variety of ways. For example, data might be collected through application forms or CVs, obtained from your passport or other identity documents, or collected from you through interviews or other forms of assessment.
We may also collect personal data about you from third parties, such as your recruitment agent, former employers, a relevant professional body, external organisations who carry out right to work checks, the Home Office, and, where applicable, external bodies which arrange assessments of applicants.
Data will be stored in a range of different places, including on your application record, in our team members management systems and in other IT systems.
Information about convictions
Whilst THE may not regularly require team members to provide information relating to criminal convictions, for some roles there may be need to provide this information. This may be where you are required.
We will only collect such information if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect it as part of the recruitment process and during your employment. We will, if appropriate use information about criminal convictions and offences to review and consider your employment considering any such information disclosed to us.
We use your personal data in this way to carry out our obligations in respect of safeguarding and to promote the legitimate interests of our business.
What if you do not provide personal data?
You are under no legal or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, we may not be able to process your application or at all. In relation to certain information, such as evidence relating to your right to work in the UK, we are under a legal obligation to obtain that information and if you do not provide it we will be unable to offer you employment
Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
During the recruitment process we may utilise an automated tool to match potential staff to available roles within the business based on the information that you provide (for example, the location you wish to work) prior to entering a contract with them. We use the information at the first stage of the recruitment process and if you application is identified by the automated tool as unsuitable based on the information that you provide then it will not progress any further. You have the right to object to automated decision-making, and you also have the right to challenge and request a review of any automated decision that is made about you.
Why do we process personal data?
We need to process data to take steps at your request prior to entering an employment contract with you. We also need to process your data to then enter an employment contract with you if your application is successful.
For example, we need to process you an employment contract with your correct details.
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required by law to check an applicant’s eligibility to work in the UK before we can employ them. We may also process your data to respond to and defend legal claims, make disclosures to law enforcement agencies or in relation to health and safety compliance and for auditing and regulatory process.
In other cases, we have legitimate interest in processing your data during the recruitment process and for keeping records about the process. Processing data from applicants allows us to manage the recruitment process, assess and confirm an applicant’s suitability for employment, and decide whether an applicant should be offered employment properly and consistently.
In relation to special categories of personal data, we may process information about your health if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to comply with our employment law obligations and exercise specific rights in relation to employment.
Where we process other special categories of personal data, such as information about ethnic origin, sexual orientation or religion or belief, this is done for the purpose of equal opportunities monitoring. This is in order that we can promote and maintain equality of opportunity, and that we can carry out monitoring which is for reasons of substantial public interest for the purpose of keeping such equality under review.
Who has access to your data?
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR team, interviewers involved in the interview process, relevant managers in the business and IT staff if access to the data is necessary for the performance of their roles. We will also share information about your application with your recruitment agency if applicable.
How do we protect your data?
We take the security of your data seriously and are committed to taking all reasonable steps to protect the data we hold. We have a range of internal policies and security controls in place to ensure that your data is not lost, accidently destroyed, misused, or disclosed, and is not accessed except by our employees who need such access in proper performance of their duties. We also have procedures and measure in place to address and respond to any potential data breach. Our security measures are kept under review and updated as appropriate.
For how long do we keep your data?
If your application for employment is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process. If you provide consent to allow us to keep your personal data on file, we will hold your data for a further 12 months for consideration of future employment opportunities that may become available after the time that you originally made your application. At the end of the relevant period, or if you withdraw your consent, your data will be deleted or destroyed.
If you application for employment is successful, personal data gathered during the recruitment process will be transferred to further internal systems and retained during your employment. A new privacy notice will be issued to you explaining how and why your data will be processed and retained if you enter employment with us.
Your rights
As a data subject, you have a number of rights. You may be able to, subject to the limitations mentioned below to:
• Make a data subject access request. You are entitled to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you.
• Request deletion of your personal data.
• Object to processing of your personal data where we are relying on a legitimate interest and your circumstances mean you want to object to processing on this ground.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend processing of personal data about you.
• Request the transfer of your personal data to another data controller.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where you object to us processing data but we have a compelling justification for continuing to process it, or you ask us to erase information which we are required by law to keep or have another compelling reason by law to keep it. As indicated above not all rights set out above apply to every type of data processing, and relevant exemptions are also included within the data protection laws which apply within the UK. We will inform you of any relevant exemptions that apply and which we rely upon when responding to any request you make.
Further information
If you have any questions about how we process your personal information please contact the Data Protection Officer at Internaldpo@timeshighereducation.com, or the Human Resources department. We hope that we will be able to address any questions or concerns you may have. However, you also have the right to make a complaint at any time to the Information Commissioner's Office (www.ico.org.uk), the UK supervisory authority for data protection issues.
