Recruitment privacy notice
Last updated May 2018
As part of any recruitment and onboarding process, Sense collects and processes personal data relating to job applicants. This is to ensure the recruitment process follows Sense policy and guidance. We are committed to being transparent about how we collect and use that data and to comply with our data protection obligations.
What information do we collect?
Sense collects and processes a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history; including start and end dates with previous employers and with Sense;
- information about your current remuneration,
- whether or not you have a disability for which Sense needs to make reasonable adjustments during the recruitment process
- information about your nationality and entitlement to work in the UK;
- information about your driving licence and use of a vehicle and
- details of any person(s) you may be related to or in a relationship with who works for Sense
- for regulated roles requiring disclosure barring service checks or AccessNI (Northern Ireland) we will collect information regarding the outcome of those checks and criminal record noted;
- information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments; and
- equal opportunities monitoring information including information about your ethnic origin, sexual orientation and religion or belief.
- date of birth and gender; this is only collected once you have been offered a job with Sense.
- details of your bank account and national insurance number; this is only collected once you have been offered a job with Sense.
- information about your marital status, next of kin, dependants and emergency contacts; this is only collected once you have been offered a job with Sense
- We will request a photograph for identification card production: this is only collected once you have been offered a job with Sense.
Sense may collect this information in a variety of ways. For example, data might be collected through application forms, CVs or resumes; obtained from your passport or other identity documents such as your driving licence or qualifications from forms completed by you during the recruitment and onboarding process; from correspondence with you; or through interviews, meetings or other assessments such as job fairs, assessment events or online psychometric test.
Sense may collect personal data about you from third parties, such as references supplied by former employers, educational establishments or personal referee’s and information from criminal records checks permitted by law. Sense will seek information from third parties and will ask for your permission to contact third parties during the recruitment process.
Data will be stored in a range of different places, including the applicant tracking system which is used to manage the recruitment process, for new starters this may include in local personnel files or folders, in the organisation's HR management systems and in other IT systems (including the organisation's email system).
Why does Sense process personal data?
The organisation needs to process data to enter into an employment contract with you and to meet its obligations under your employment contract. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts and it needs to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer pension and other benefits.
There are two lawful bases for processing your data. These are legal obligations and legitimate interest.
In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee's entitlement to work in the UK.
In other cases, the organisation has a legitimate interest in processing personal data during the recruitment process for example processing data from job applicants allows
- the organisation to manage the recruitment process
- the organisation to assess and confirm a candidate's suitability for employment and
- the organisation to decide to whom to offer a job.
- This may include obtaining occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law.
- ensure effective general HR and business administration; and
- respond to and defend against legal claims.
Where Sense processes other special categories of personal data, such as information about ethnic origin, sexual orientation or religion or belief, this is done for the purposes of equal opportunities monitoring. This is to carry out its obligations and maintain specific rights in relation to employment.
Some special categories of personal data, such as health or medical conditions, is processed to carry out employment law obligations such as those in relation to employees with disabilities where we are identified as a Disability Confident Employer.
For some roles, Sense is obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
Sense will not use your data for any purpose other than the recruitment exercise for which you have applied for. If your application is unsuccessful, Sense may keep your personal data on file in case there are future employment opportunities for which you may be suited. Sense will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
Who has access to data?
Your information may be shared internally, including with members of the HR and recruitment team, payroll, your line manager, managers in the business area in which you work and IT staff if access to the data is necessary for performance of their roles.
Sense shares your data with third parties in order to:
- Obtain pre-employment references from other employers
- Obtain employment background checks from third-party providers
- Obtain necessary criminal records checks from the Disclosure and Barring Service or Access NI.
- Process data on its behalf in connection with the provision of benefits such as pensions and other benefits through 3rd parties in order to meet the requirements of those benefits providers.
- We will also provide (with your consent) information for the provision of occupational health services.
The organisation does not have any intention to transfer your application data to countries outside the European Economic Area.
How does the organisation protect data?
Sense takes the security of your data seriously. The organisation has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.
There is restricted access to our people data systems with specific permissions allocated to individuals on a need to know basis. So for example, the recruitment team and recruiting managers will have access to job application forms and line manager will be able to access relevant information to help them manage the recruitment process.
Some special categories of sensitive data such as information about ethnic origin, sexual orientation or religion or belief will be restricted to access within the Human Resources Team.
Where the organisation engages third parties to process personal data on its behalf, they do so on the basis of a written contract, which means they are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
For how long does the organisation keep data?
If your application for employment is unsuccessful, Sense will hold your data on file for six months after the end of the relevant recruitment process. In some cases, it may be that Sense want to keep your application on file for future employment opportunities on the basis that you agree to allow Sense to keep your personal data on file, Sense will obtain your permission and will hold your data on file for a further six months. At the end of that period or once you withdraw your consent, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your employee file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice. Your personal data will be deleted from the applicant tracking system after 24 months.
To ensure adequate time for appropriate assessment and review, notice of offences and criminal records retention will be restricted to six months in line with Disclosure Services Barring Service guidance.
What if you do not provide personal data?
You have some obligations as part of the recruitment process to provide the organisation with data for us to consider your application and to fulfil our legal obligations.
For successful candidates, certain information, such as contact details, your right to work in the UK and payment details, have to be provided to enable the organisation to enter a contract of employment with you. If you do not provide other information, this will hinder the organisation's ability to administer the rights and obligations arising as a result of the employment relationship efficiently.
Employment decisions within Sense are not based solely on automated decision-making.
As a data subject, you also have a number of rights. You can:
- access and obtain a copy of your data on request;
- require the organisation to change incorrect or incomplete data;
- require the organisation to delete or stop processing your data when the data is no longer necessary for the purposes of processing; and
- object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing
If you would like to exercise any of these rights or have specific questions about your information and confidentiality, please contact HR@sense.org.uk for further guidance.
If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.
Sense privacy notice