Introduction and scope of privacy notice
This Recruitment Privacy Notice explains the type of information we process, why we are processing it and how that processing may affect you
What do we mean by "personal data" and "processing"?
"Personal data" is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you, but also intentions and opinions about you.
"Processing" means doing anything with personal data. For example, it includes collecting it, holding it, disclosing it or deleting it.
Your personal data
We process your personal data for the purposes of fulfilling our recruitment practices. Some of the personal data that we process about you comes from you. For example, you tell us your contact details, like your first and last name, email address, and phone number. Other personal data about you is generated from references and third party companies such as recruitment agencies, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google. As part of the recruitment process you will be asked to complete some tests through a system called McQuaig. McQuaig act as a data processor, your data will be stored on their platform and may be used for profiling roles when you join the business. Your personal data will be seen internally by managers, administrators and HR. We may also share your data with external law firms for assessment of employment permits and visa options.
During the recruitment process, we try not to collect or process any “Sensitive Personal Information” unless authorised by law or where necessary to comply with applicable laws. Sensitive Personal Information includes the following: information that reveals your racial or ethnic origin, religious, political, or philosophical beliefs, or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health, sex life, or sexual orientation.
Our privacy notice for job applicants
The Company is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with GDPR, the types of data that we collect and hold on you as a job applicant. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
Data controller details
The Company is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: The Beans Group Limited (registered number 5486885) whose registered office is at 1 Vincent Square, London, SW1 2PN.
Data protection principles
In relation to your personal data, we will:
process it fairly, lawfully and in a clear, transparent way
collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
only use it in the way that we have told you about
ensure it is correct and up to date
keep your data for only as long as we need it
process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed
Why we process your data
The law on data protection allows us to process your data for certain reasons only:
in order to perform the employment contract that we are party to
in order to carry out legally required duties
in order for us to carry out our legitimate interests
to protect your interests and
where something is done in the public interest
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
We need to collect your data to ensure we are complying with legal requirements such as:
carrying out checks in relation to your right to work in the UK and
making reasonable adjustments for disabled employees
We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:
making decisions about who to offer employment to
making decisions about salary and other benefits
assessing training needs
dealing with legal claims made against us
If you are unsuccessful in obtaining employment, we may seek your consent to retaining your data in case other suitable job vacancies arise in the Company for which we think you may wish to apply. You are free to withhold your consent to this and there will be no consequences for withholding consent.
We must process special categories of data (“Sensitive Personal Information”) in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
you have given explicit consent to the processing
we must process the data in order to carry out our legal obligations
we must process data for reasons of substantial public interest
you have already made the data public
We will use your special category data:
for the purposes of equal opportunities monitoring
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
Criminal conviction data
We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment should you be successful in obtaining employment.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not able to process, or continue with (as appropriate), your application.
Who gets to see your data?
Your personal data may be disclosed to managers, HR and administrators for employment, administrative and management purposes as mentioned in this document. We may also share your data with external law firms for assessment of employment matters, permits, and visa options. We may also disclose this to other members of our group.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
The main data processor we use for processing job application data and communications is Workable and also G-suite. Both of which may store data with Amazon Web services in the US. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for and this will depend on whether or not you are successful in obtaining employment with us.
If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for six months once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for one year once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
the right to portability. You may transfer the data that we hold on you for your own purposes the
right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact us at firstname.lastname@example.org
Making a complaint
The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.