Candidate privacy notice
Last updated - 27 November 2019
Notting Hill Genesis ("NHG", "we" or "us") is committed to protecting the personal data of its employees. This Notice sets out important information about how NHG collects and uses your personal data during the course of the application and recruitment process.
You should read this Notice carefully and raise any questions you may have with the HR team or with NHG's designated Data Protection Officer (further details below).
This Notice applies to all UK job applicants/candidates. In connection with the recruitment process, the relevant data controller is Notting Hill Genesis, with registered society number RS007746 and whose registered office is Bruce Kenrick House, 2 Killick Street, London N1 9FL.
What personal data do we collect?
Personal data means information which identifies you and relates to you as an individual. As your prospective employer, NHG will collect, use and store your personal data for a wide variety of reasons in connection with the job application and recruitment process. We have set out below the main categories of candidate personal data which we process in connection with our recruiting activities on a day to day basis:
- personal contact information (including your name, home address, personal telephone number(s) and personal e-mail address)
- work history and other relevant experience including information contained in CV, cover letter or job application form
- education information including degrees awarded, transcripts and other information provided in support of the job application
- compensation history
- information collected during phone screenings and interviews
- details regarding the type of employment sought, desired salary, job preferences, and other information related to compensation and benefits
- reference information and information received from background checks (where applicable) including information provided by third parties
- information related to previous applications to us or previous employment history with us
- documents evidencing your right to work (including information about your immigration status where relevant, registration under the CIS scheme where applicable and relating to your ability to drive/possession of valid driving licence)
- date of birth
- information gathered through NHG's monitoring of its IT systems, building access records and CCTV recording in relation to your communications with us and attendance at our premises.
The majority of the personal data to be provided by you is mandatory in connection with our recruiting activities. Failure to provide mandatory personal data may affect our ability to accomplish the purposes stated in this Notice, including considering your suitability for employment and/or entering into an employment contract with you.
The list set out above is not exhaustive, and there may be other personal data which NHG collects, stores and uses in the context of the application and recruitment process. NHG will update this Notice from time to time to reflect any notable changes in the categories of personal data which it processes.
The majority of the personal data which we process will be collected directly from you. However, your personal data may also be provided to us by third parties, such as recruitment agencies, former employers, official bodies (such as regulators or criminal record bureaus), medical professionals and/or or through selected third parties with whom NHG contracts in order to undertake checks or validations.
Referencing and vetting
As part of our referencing and vetting procedures, we will contact certain third parties in order to verify your personal information (including personal information that you provide as part of the application and recruitment process). These third parties will include:
- former employers in order to verify your previous employment history
- universities and/or other establishments for higher education that you attended in order to verify your education history
- credit reference agencies.
- Benefit Agencies e.g Job centres
We will only seek this information in relation to successful candidates that have accepted a conditional offer of employment with us and we will specifically inform such candidates that we will be contacting these third parties in advance of doing so.
How do we use your personal data?
NHG uses your personal data for a variety of purposes in order to take steps necessary to enter into an employment contract with you, to comply with legal obligations or otherwise in pursuit of its legitimate business interests. We have set out below the main purposes for which candidate personal data is processed:
- to identify and evaluate job applicants, including assessing skills, qualifications and experience
- verifying candidate information and carrying out employment, background and reference checks, where applicable and in order to prevent fraud
- communicating with you about the recruitment process and your application
- to comply with our legal, regulatory, or other corporate governance requirements.
In addition to using your personal data to consider you for the role you applied for, we will retain and process your personal data to inform you about, and to consider you for, other roles that may be appropriate for you. If you do not want us to consider you for other roles which we consider may be appropriate for you, please inform your HR contact.
Again, this list is not exhaustive, and NHG may undertake additional processing of personal data in line with the purposes set out above. NHG will update this Notice from time to time to reflect any notable changes in the purposes for which it processes your personal data.
What special categories of personal data do we process?
- Health Information
We may process information about a candidate's physical or mental health in compliance with our obligations owed to disabled employees. Some of this information is collected during the course of the application process, including to enable us to identify any reasonable adjustments we may need to make during the application/recruitment process and to assess suitability for certain roles where there are applicable health and safety requirements we need to comply with. This information is collected through questionnaires which candidates are asked to complete.
We will always treat information about health as confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.
If a candidate is successful, any health information processed as part of the recruitment process that is relevant to NHG's compliance with its obligations in connection with employment will be retained and processed in accordance with the Employee Privacy Notice.
If a candidate is unsuccessful, any health information obtained as part of recruitment process will be deleted with the rest of the candidate's personal data within 6 months of their rejection.
- Criminal Record Information
Given the nature of our business, we may ask successful candidates who have accepted a conditional offer of employment to disclose their criminal record history and we carry out criminal record checks, including using vetting and checking agencies, as part of our background vetting process and in compliance with our obligations in connection with employment and, for certain parts of our business (for example, for regulated Care & Support roles), to comply with regulatory and legal obligations. In all cases, we carry out the checks in accordance with the applicable law.
We will always treat criminal record history as confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure.
Criminal record information will be deleted once the recruitment process has been completed, subject to any exceptional circumstances and/or to comply with particular laws or regulations in which case criminal record information will typically be retained for a maximum of 6 months (unless we need to keep it for longer for legal purposes), although the outcome of any check will remain on the candidate's record.
- Equal Opportunities Monitoring
NHG is committed to providing equal opportunities for employment to all candidates and from time to time it will process information relating to ethnic origin, race, nationality, sexual orientation and disability, alongside information relating to gender and age, for the purposes of equal opportunities monitoring.
We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure. In addition, this monitoring will always take place in accordance with appropriate safeguards as required under applicable law, including:
- the provision of information relating to ethnic origin, race, nationality, sexual orientation and disability for the purposes of monitoring will be voluntary and processed for this purpose only with your consent;
- wherever possible, the monitoring will be conducted on the basis of using anonymised data so individual candidates cannot be identified;
- the information processed for monitoring purposes will be maintained separately from general management and HR records.
When do we share employee personal data?
NHG will share candidate/prospective employee personal data with other parties only in limited circumstances in order to take steps necessary to enter into the employment contract or where necessary to comply with a legal or regulatory obligation, or otherwise in pursuit of NHG's legitimate business interests as follows:
- recruitment agencies
- background vetting specialists
- occupational health providers
- HMRC and/or any other applicable government body
- accountants, lawyers and other professional advisers
- appropriate regulatory agencies.
- managed service providers
In all cases, with the exception of information which we are required to provide to regulatory agencies, the candidate/prospective employee personal data is shared under the terms of a written agreement between NHG and the third party which includes appropriate security measures to protect the personal data in line with this Notice and our obligations. The third parties are permitted to use the personal data only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission.
For how long with my personal data be retained?
NHG's policy is to retain personal data only for as long as needed to fulfil the purpose(s) for which it was collected, or otherwise as required under applicable laws and regulations. Under some circumstances we may anonymise your personal data so that it can no longer be associated with you. We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice to you.
For unsuccessful candidates:
- We will typically retain personal data collected during the recruitment process for a maximum period of 6 months from the end of the process subject to any exceptional circumstances and/or to comply with particular laws, regulations or regulatory requirements.
- We may retain select data relating to particular candidates on file for a longer period than 6 months in order to follow up with the candidates in relation to future vacancies; if you do not wish for your personal data to be maintained on file for this purpose, please inform us.
- We will typically retain personal data held in archived e-mails or other electronic files for 6 months from the end of the recruitment process.
If you are offered and accept employment with us, the personal data we collected during the application and recruitment process will become part of your employment record and we may use it in connection with your employment in accordance with the Employee Privacy Notice.
What are my rights in relation to my personal data?
NHG will always seek to process your personal data in accordance with its obligations and your rights.
You will not be subject to hiring decisions based solely on automated data processing without your prior consent.
In certain circumstances, you have the right to seek the erasure or correction of your personal data, to object to particular aspects of how your data is processed, and otherwise to seek the restriction of the processing of your personal data. You also have the right to request the transfer of your personal data to another party in a commonly used format. If you have any questions about these rights, please contact NHG's Data Protection Officer using the details set out below or, alternatively, a member of the HR team.
You have a separate right of access to your personal data processed by NHG. When exercised by you, you may be asked for information to confirm your identity and/or to assist NHG to locate the data you are seeking as part of NHG's response to your request. If you wish to exercise your right of access you should set out your request in writing to NHG's Data Protection Officer using the details set out below.
Finally, you have the right to raise any concerns about how your personal data is being processed by NHG with the Information Commissioner's Office (ICO) by going to the ICO's website: https://ico.org.uk/concerns/ or contacting the ICO on 0303 123 1113 or firstname.lastname@example.org.
Where can I get more information?
NHG has appointed a Data Protection Officer to oversee compliance with this Notice and to deal with any questions or concerns. If you would like further information about the matters set out in this Notice, please contact the Data Protection Officer or, alternatively a member of NHG's HR team.
The contact details for the Data Protection Officer are set out below:
Telephone: 020 7563 0042