Processing of (personal) data by the entity in charge of the online application process
Notpla Recruitment Privacy Notice
Notpla Limited is a “controller” in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. You have access to this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR).
We take your privacy seriously and we are fully committed to protecting your personal data at all times. We will only process your personal data in accordance with, and adhere to the principles (as applicable) contained within, the UK General Data Protection Regulation (UK GDPR)..
This notice does not form part of any offer of employment and we may amend it at any time to reflect any changes in the way in which we process your personal data. If you are in the application process when any changes or updates are made to this notice, we will bring any such changes to your attention as soon as is practicable. We may also notify you in other ways from time to time about the processing of your personal data.
Data Protection Principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you
“Personal data” is any information we hold about you in the form of your application for any vacancies you have applied for with Notpla.
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:-
- The information you have provided to us in your curriculum vitae and any covering letter.
- The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, visa and/citizenship status.
- Any information you provide to us during an interview.
We may also collect, store and use the following types of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
When we refer to “processing”, this means anything from collecting, using, storing, transferring, disclosing, altering or destroying personal data.
The data we collect
We collect personal information about candidates from the following sources: –
- You, the candidate.
- Recruitment agency.
- Job board or your LinkedIn Profile.
- Your named references.
The personal data we may collect from you personally includes: –
- Contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Copies of driving licence, passport, birth certificates and proof of current address, such as bank statements and council tax bills.
- Evidence of how you meet the requirements of the job, including CVs and references.
- Evidence of your right to work in the UK and immigration status, such as passport and visa documentation.
- Other information required for some applications.
- If you contact us regarding your application, a record of that correspondence.
- The status of your application and updates on how it moves forward.
How we use your personal data
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the work role.
- Progress your application.
- Keep records related to our hiring process.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
- Any reasonable adjustments that you require for the purpose of interview.
- Where you have consented for us to do so.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
It is in our legitimate interests to decide whether to appoint you into the role since it would be beneficial to our business to appoint someone to that role. Further, it is in our legitimate interests to decide whether to appoint you to work at Notpla since it would be beneficial to our business.
We also need to process your personal information to decide whether to enter into a contract of employment or engagement (whichever is appropriate) with you.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
Information about criminal convictions
We do not envisage that we will process information about criminal convictions.
Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Data Storage and Security
Your personal data and special category personal data is stored in a variety of locations, including: electronically on our HR System and GSuite.
We take appropriate technical and organisational security measures and have rules and procedures in place to guard against unauthorised access, improper use, alteration, disclosure and destruction and accidental loss of your personal data.
In addition, we limit access to your personal data to those who have a business need to know and they will only process your personal data on our instructions and subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected or actual data security breach and will notify you and the Information Commissioner’s Office (“ICO”) of a suspected breach where we are legally required to do so.
Whenever we propose using new technologies, or where processing is construed as ‘high risk’, we are obliged to carry out a data protection impact assessment which allows us to make sure appropriate security measures are always in place in relation to the processing of your personal data.
Data Retention
We keep your personal data and special category personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Information about how long we retain such personal data is set out below.
When applying for a job with us, we compile and keep an electronic email folder containing information about you which relates to your application for a job with us. Your information will be kept secure and will be used for the purposes of your job application, as explained above. This information will be kept as an electronic file.
We welcome speculative applications and if you apply for a job with us and we don’t have a suitable opening at the time we will email you to inform you that your application will be held in our electronic talent bank for a period of 6 months after your most recent application.
For documents supporting the application process, the retention period is 6 months. If you are unsuccessful, personally identifiable data is removed 6 months after your most recent application.
If you are offered and you accept a job with us, your personal data will be transferred to an electronic personnel file. Any hard copy personnel file will be kept in locked filing cabinets.
Your responsibilities
We encourage you to ensure that the personal data that we hold about you for the purposes of your application or for the purposes of considering you for any similar roles is accurate and up to date by keeping us informed of any changes to your personal data. You can update your details by contacting the CFO/COO or a CoFounder.
The way we process your personal data and the lawful basis on which we rely to process it may affect the extent to which these rights apply. If you would like to exercise any of these rights, please address them in writing to the CFO/COO or a CoFounder.
We may need to request specific information from you to help us to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Rights of Access, Correction, Erasure and Restriction
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact fern@notpla.com or legal@notpla.com
Right to withdraw Consent
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time.
To withdraw your consent, please contact the CFO/COO or CoFounder.Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If you withdraw your consent, our use of your personal data which was collected before your withdrawal is still lawful.
You have the right to complain to a supervisory body if you are concerned about the way we have processed your personal data. In the UK this is the ICO – www.ico.org.uk. Although you have the right to complain to the ICO, we encourage you to contact us first with a view to letting us help in resolving any queries or questions.
QUESTIONS
If you have any questions about any matter relating to data protection or the personal data and/or special category personal data that we process about you, please contact our Office Manager on fern@notpla.com