65 Carter Lane
EC4V 5DY London, UK
Recruitment Privacy Notice
5.1.1 This privacy notice explains what personal information we collect and hold about candidates and how we will use that information during the application and recruitment process.
5.1.2 The information within this privacy notice will be provided to candidates who have applied for an advertised vacancy and been shortlisted, and also to applicants who have informally applied for a role or speculatively enquired about an opportunity.
Collection of personal data
5.1.3 We collect personal information directly from candidates in circumstances where they wish to apply for a position with us, whether this is online, through emails to us, or otherwise.
We may also learn about applicants through third parties such as recruitment agencies, where an employee recommends an applicant, or from other sources such as LinkedIn. If a candidate is successful, we may also collect information about them from previous employers.
This privacy notice applies in respect of all recruitment activity whether applicants have provided personal information directly to us or it has been provided to us through a third party.
Use of personal data
5.1.4 All of the information provided by candidates during the application process will only be used for the purpose of progressing their application, or to fulfil legal or regulatory requirements if necessary.
5.1.5 We do not collect more information than we need to fulfil our stated purposes and we will not retain it for longer than is necessary.
5.1.6 Plastic Energy is the data controller with regards to personal data collected during the recruitment process. This means that we are responsible for deciding how we hold and use personal information about applicants.
5.1.7 A controller may only process personal information where there is a lawful basis allowing them to do so. When we process personal information during the recruitment process, generally, we will rely on the following lawful bases:
- We need to process data to take steps, at the applicant’s request, prior to entering into a potential contract with them.
- In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check an applicant’s eligibility to work in the UK before employment starts.
- We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from applicants allows us to manage the recruitment process, assess and confirm their suitability for employment and decide to whom to offer a job. We may also need to process data from applicants to respond to and defend against legal claims.
- We may use the basis of legitimate interest to transfer an applicant’s personal data to another company within the Plastic Energy Group where an employee of another entity within our company group is directly involved with the recruitment and selection process. This may be within the EEA or outside of the EEA.
- In addition, we may process information about whether applicants have a disability, to make reasonable adjustments and to carry out our legal obligations and exercise specific rights in relation to employment practices.
5.1.8 In connection with the above specified purposes, we may collect, store, and use the following personal information about applicants:
- The information applicants have provided to us in their CV and covering letter. ➢ Any information they provide to us during an interview.
- Information provided to us by an applicant’s referee(s).
- Information applicants provide in relation to their right-to-work documentation.
5.1.9 We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about their health, if they request us to make any reasonable adjustments to the recruitment and selection process.
5.1.10 Applicants’ information will be shared internally only for the purposes of the recruitment exercise. This includes Human Resources, the hiring manager and the senior manager in the business area with a vacancy. The information will be held securely by us in electronic or paper format.
5.1.11 We will not share candidates’ data with anyone else, unless their application for employment is successful and we make them an offer of employment. We will then share their name and the role they are applying for with their current or former employers to obtain references. We will ask candidates to supply the contact details of such referees.
5.1.12 Candidates are under no obligation to provide data to us during the recruitment process. However, if they do not provide the information, we may not be able to process their application properly or at all.
5.1.13 We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to applicants’ personal information to those who have a genuine business need to know it.
Those processing applicants’ personal information will do so only in an authorised manner, and are subject to a duty of confidentiality.
5.1.14 We have procedures in place to deal with data security breaches. We will notify applicants and any applicable regulator of a data security breach, where we are legally required to do so.
Retention of personal data
5.1.15 If an application for employment is unsuccessful at any stage of the process, we will hold the applicant’s data on file for up to 12 months after the end of the relevant recruitment process. After this period, we will securely destroy their personal information.
5.1.16 Information generated by us throughout the assessment process, for example interview notes, may also be retained for 12 months following the closure of the campaign.
5.1.17 If a candidate is unsuccessful, we may ask if they would like their details to be retained in our talent pool for a period of up to 12 months. If they provide their consent, we will proactively contact them should any further suitable vacancies arise.
5.1.18 If an applicant applies speculatively to us, for example they send us their CV should any opportunities arise, and if we wish to retain their data, we will ask them if they would like their details to be retained in our talent pool for a period of up to 12 months. If they provide their consent, we will proactively contact them should any suitable vacancies arise.
5.1.19 If a candidate is successful in their application and joins the company, their personal data collected during the recruitment process will be transferred to their personnel file and we will retain their information in accordance with our Data Protection Policy_Data_Protection_Policy.
5.1.20 Applicants have the right to:
- Request access to their personal information (known as a ‘data subject access request’).
- Request that we correct incomplete or inaccurate personal information that we hold about them.
- Request us to delete or stop processing their personal data, for example where the data is no longer necessary for the purposes of processing.
- Object to the processing of their data where we are relying on our legitimate interests as the legal ground for processing.
- Request we restrict the processing of their personal data – they can ask us to stop processing their personal information, for example if they want us to establish its accuracy, or the reason for processing it.
- Request the transfer of their personal data to another party.
- Withdraw consent – in the limited circumstances where they have provided their consent to the collection, processing and transfer of their personal information for a specific purpose, they have the right to withdraw their consent for that specific processing at any time.
If an applicant would like exercise any of their rights, they should use the contact details provided below.
5.1.21 If a candidate has any queries, concerns or requests about this recruitment privacy notice, or they should contact us at firstname.lastname@example.org. Alternatively they can contact us by writing to:
The Human Resources Manager, Plastic Energy Limited, 65 Carter Lane, London. EC4V 5DY.