As part of any recruitment process, Bond International Software (UK) Limited and Tempbuddy Limited t/a erecruit (hereafter known as “the Company”) collects and processes personal data relating to job applicants. The Company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
Your personal data is processed by the Company when you apply, which will be the data controller of that personal data. The Company may pass all or part of your data between other relevant group companies, such affiliated operating companies in other regions of the world, parent companies and holding companies, to the extent permitted under law applicable law for the purpose of your recruitment selection and if you are taken on, as part of your employment.
What information does the Company collect?
As part of the recruitment process, the Company collects 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;
- information about your current level of remuneration, including benefit entitlements;
- whether or not you have a disability for which the Company needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief should you choose to provide this.
The Company collects this information in a variety of ways. For example, data might be contained in application forms, CVs/resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
The Company will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. The Company will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Where reasonably necessary or required to do so, the Company may disclose these details to third parties in relation to law enforcement or regulatory investigation and also for the purpose of conducting any pre-employment checks (to the extent that these are permitted under local law).
Data will be stored in a range of different places, including on your application record, in the Company’s HR management system and in other IT systems (including our email system).
If you are taken on to work at the Company, other personal data will be collected and processed about you in accordance with our employee privacy notice.
Why does the Company process personal data?
The Company needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
We shortlist applicants using a manual selection process, considering appropriate experience and skills for the job.
What legal basis does the Company have for using personal data?
In general, the Company processes your personal data in order to assess your application prior to entering into an employment contract with you, and pursuant to laws which the Company is subject to. This processing is a necessary pre-condition of entering into any future contract with you and for the Company to fulfil its obligations with respect to other employees and yourself (should you be employed by the Company). If you are unable to provide the Company with the information requested, the Company may be unable to assess your appropriateness for the job applied for or to communicate with you.
In some cases, the Company needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
The Company also has legitimate interests in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the Company to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The Company may also need to process data from job applicants to respond to and defend against legal claims.
Where the Company relies on legitimate interests as a reason for processing data, it has taken into account your data protection rights. If you have any questions about the assessment the Company has made in order to rely on this legal basis, please contact the Company using the details below.
Where the Company processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability this is processed to carry out its legal obligations and exercise specific rights in relation to employment.
For some roles, the Company is obliged to seek information about unspent criminal convictions and offences. Where the Company seeks this information, it again does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
If your application is unsuccessful, the Company will keep your personal data on file in case there are future employment opportunities for which you may be suited. The Company 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 will be shared internally for the purposes of the recruitment exercise. This includes members of the HR team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
Subject to the below, the Company will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The Company will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and Disclosure Scotland to obtain necessary criminal records checks.
The Company may, where required, share your personal data in relation to law enforcement or regulatory investigations.
When do we send your personal data abroad?
We hold your personal data principally in the country in which you apply for a role. However, your data may be transferred to countries outside the European Economic Area (EEA) to ensure effective general HR and business administration with our group companies offices and other third parties with a legitimate interest in obtaining such personal data such as officers and senior executives of the group companies, individual members of the Board of Directors, legal and financial consultants advisors, and actual or potential investors in the group companies.
The Company will ensure that, in respect of such transfers, an appropriate level of protection is given to the personal data (and uses EU approved “Model Clauses” where appropriate in order to ensure this). You can contact us as per below for more information about this.
How does the Company protect data?
The Company takes the security of your data seriously. It has appropriate technical and organizational measures, policies and controls in place to reduce the risk that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. All systems containing employee data are password protected, there is restricted access and the Company provides a Data Protection policy.
For how long does the Company keep data?
If your application for employment is unsuccessful, the Company will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow the Company to keep your personal data on file, the Company will hold your data on file for a further 6 months for consideration for future employment opportunities. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed. However, deletion of files may be suspended where required by law or to defend ourselves if we consider a complaint or dispute to be likely.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel 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.
If you are situated within the EEA, as a data subject, you have a number of rights in relation to your personal data. Please be aware that certain exceptions apply to the exercise of these rights and so you will not be able to exercise these in all situations. If you wish to exercise any of the rights set out above, the Company will endeavour to respond to your request within a reasonable timescale.
- Subject Access: you have a right to be provided with access to any data held about you by the Company and to obtain a copy of your data, generally within 1 month of your request.
- Rectification: require the Company to change incorrect or incomplete data.
- Erasure: require the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing.
- Withdrawal of consent: You can withdraw any consents to processing that you have given us and prevent further processing if there is no other ground under which the Company can (and does) use to justify the processing your personal data.
- Restriction: You can require certain personal data to be marked as restricted whilst complaints are resolved and also restrict processing in certain other circumstances.
- Portability: You can ask us to transmit the personal data that you have provided to us and we still hold about you to a third party electronically.
- Prevent processing:where the Company is relying on its legitimate interests, ask the Company to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the Company’s legitimate grounds for processing data.
Your contact for any queries
If you have any questions relating to the Company’s use of your personal data or would like to exercise any of these your data subject rights, please contact HR at firstname.lastname@example.org. If you believe that the Company has not complied with your data protection rights, you can complain to the Information Commissioner’s Office by calling 0303 123 1113 or writing to Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. You also have the right to contact the data protection regulator in the EEA country in which you are based. A list of the data protection regulators and their contact details can be found at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the Company during the recruitment process. However, if you do not provide the information, the Company may not be able to process your application properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information. Where you provide us with Special Categories of Personal Data for this purpose, we justify our processing of this data on the ground that it is within the substantial public interest (equality of opportunity or treatment).