GDPR – Recruitment
Privacy Statement: Job Applicants
DOHR Limited is committed to respecting and protecting your privacy and the confidentiality of any information that you provide us with. The purpose of this statement is to set out how and why we collect, store, use and share any personal information that we may obtain from you and to detail your rights in relation to it. DOHR comply with the General Data Protection Regulation and Data Protection Act and are responsible as a ‘controller’ for the purposes of those Regulations.
- ‘Personal data’: data by which a living individual may be identified
- ‘Processing’: obtaining, recording or holding, or carrying out any operation or set of operations
- ‘Data Controller’: determines the purpose and means in which data is processed
- ‘Data Processor’: processes personal data on behalf of the data controller
Use and collection of personal information
As part of any recruitment process, DOHR collects and processes a range of information about you. This may include:
- Information by which you can be personally identified, such as your name, address, contact details including but not limited to email addresses and telephone numbers, details of your education, qualifications, skills, experience and employment history.
- Information about your current level of remuneration, including benefit entitlements.
- Information about whether or not you have a disability for which reasonable adjustments may need to be made during the recruitment process.
- Information about your entitlement to work in the UK.
- Reference information including sickness absence and parental leave records.
- Information which does not identify you as an individual, such as technical information which may be provided to us automatically as you navigate through the website (e.g. usage details, location-based information) and from third parties such as social media or recruitment sites or where you have clicked through to our website.
We may collect this information in a variety of ways. For example, data might be from an online profile contained in application forms, your CV, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
We may 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. We 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.
Data will be stored in a range of different places, including on your application record, in our recruitment management system and on our other IT systems (including email).
Your knowledge and consent of DOHR collecting, using and disclosing your personal information is critical in order to provide recruitment services to you. We rely on any of the following actions by you as indications of your consent:
- your voluntary provision of personal information directly to us;
- where we download your details from an external recruitment site such as Reed or CV library – you are responsible for removing your details if you no longer wish to be contacted with potential jobs;
- your acceptance of this privacy statement which will be sent to you, until such time as you notify us in writing withdrawing your consent.
Your direct consent may not be required from you, where we process your personal information which is necessary for the performance of a contract or to enter into a contractual relationship with you or if it is necessary for genuine and legitimate business interests.
Why do we process your personal data?
DOHR needs to process your data as part of the recruitment process. It may also need to process your data to establish whether you wish to be considered for a job with us or one of our clients.
In some cases, we need to process data to ensure we are complying with our legal obligations. For example, if we are required to check a successful applicant’s eligibility to work in the UK before employment starts.
We and our clients have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
We may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. We may also collect information about whether or not applicants are disabled to enable us during the recruitment process to make reasonable adjustments for candidates who have a disability. We process such information to carry out our obligations and exercise specific rights in relation to employment.
For some roles, we are obliged to seek information about criminal convictions and offences. Where we or our clients require this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment. You will need to be involved in this process and your express consent may be required.
If your application is unsuccessful, we may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before we keep your data for this purpose and you are free to withdraw your express consent at any time.
Who has access to your personal data?
Your information may be shared internally for the purposes of recruitment. This includes members of the HR and recruitment 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.
Where we are recruiting for a DOHR client, your information will also be shared externally with prospective employers or recruiters. However, you will always be contacted by a member of our team to verify your details and interest before your details are sent to any prospective employers and your details, excluding your contact details, will only be sent with your express verbal or written consent.
We will not share your contact details with any other third parties, unless your application for employment is successful and they make you an offer of employment. We may then share your data with your prospective employer to enable them to commence the onboarding process.
Where we provide outsourced HR services to our clients, we will ask you to provide further information so that we can contact your former employers to obtain references for you. We may also ask you to provide additional information to enable Right to Work and DBS checks to be obtained.
How do we protect data?
DOHR takes the security of your data seriously. We have internal technical and organisational measures in place to protect any personal information we process about you to ensure that your data is not lost; accidentally destroyed, misused or disclosed; and is not accessed except by its employees or contractors in the performance of their duties. All information you provide to us is stored on our secure servers behind firewalls.
Unfortunately, no data transmission over the internet is guaranteed to be 100% secure and as a result you acknowledge that there are security and privacy limitations of the internet which are beyond our control. The safety and security of your information is also dependant on you. In the event that personal data is compromised as a result of breach of security, we will notify everyone affected in accordance with the notification procedure set out in this privacy statement or as otherwise required by applicable law.
Where we engage third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
How long do we keep data?
If your application for employment is unsuccessful, we will hold your data on file for 6 months’ after the end of the relevant recruitment process. If you agree to allow us to keep your personal data on file, we will hold your data on file for a further year for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data is deleted and/or destroyed.
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 with your new employer. Where we provide HR support to your employer, we may also retain details of your personnel file for the purposes of administering your employment. The periods for which your data will be held will be provided to you in a privacy notice and/or policy.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require us to change incorrect or incomplete data;
- withdraw your consent or require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where we are relying on its legitimate interests as the legal ground for processing and
- object at any time to the processing of personal information for direct marketing purposes
If you would like to exercise any of these rights, please contact firstname.lastname@example.org and let us know the information to which you request relates.
We hope we can resolve any query or concern you raise about our use of your information. If you believe that DOHR has not complied with your data protection rights, you can complain to the Information Commissioner.
Payment of a fee will not be charged for any request for access to your data unless the request is manifestly excessive or unfounded under the General Data Protection Regulation.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, certain information, such as names, address and contact details must be provided to enable us to provide this service to you. If you do not provide certain information, this may hinder our ability to process your application properly or at all.
DOHR do not base decisions solely or partially on automated decision-making.
Notices and Revisions
If you have any concern about your privacy or this privacy statement, please e-mail a thorough description and we will try to resolve the issue for you. Our business changes constantly and our Privacy Statement, Terms & Conditions may change too. Any changes, modifications, additions or deletions shall be effective immediately upon notice, which shall be given by means including but not limited to, issuing an email to the email address listed and/or posting a notice and the revised policy on the website. You acknowledge that it is your responsibility to maintain a valid email address, and to review the site and privacy statement periodically in order to be aware of any modifications. Your continued use of the services after such modification will constitute your acknowledgement of the modified statement and agreement to be bound by it.
Data Controller and Data Protection Officer:
PO Box 1159