This Job Applicant Privacy Notice sets out what personal data we, HUBER+SUHNER Polatis Ltd, hold about you and how we collect and use it during and after the recruitment process. It applies to anyone who is applying to work for us, whether as an employee, worker, contractor, consultant, intern, volunteer, partner or director (together referred to as ‘Job Applicant’ or ‘you’).
Please note that we will not necessarily hold, use or share all of the types of personal data described in this Privacy Notice in relation to you. The specific types of data about you that we will hold, use and share will depend on the role for which you are applying, the nature of the recruitment process, how far you progress in the recruitment process and your individual circumstances.
We are required by data protection law to give you the information in this Privacy Notice. It is important that you read the Privacy Notice carefully, together with any other similar or additional information that we might give you from time to time about how we collect and use your personal data.
Should your application be successful, when you start work for us, we will provide you with another privacy notice that explains how we deal with your personal data whilst you are working for us.
This Privacy Notice applies from 25 May 2018, when the General Data Protection Regulation comes into force. It does not give you any contractual rights. We may update this Privacy Notice at any time.
Who is the controller?
HUBER+SUHNER Polatis Ltd, 332 Science Park, Milton Road, Cambridge, CB4 0WN, is the “controller” for the purposes of data protection law. This means that we are responsible for deciding how we hold and use personal data about you.
Our HR Manager, HUBER+SUHNER Polatis Ltd, is our Data Privacy Officer (DPO).
As DPO, they are responsible for informing and advising us about our data protection law obligations and monitoring our compliance with these obligations. They also act as your first point of contact if you have any questions or concerns about data protection.
What is personal data?
means any information relating to a living individual who can be identified (directly or indirectly) in particular by reference to an identifier (e.g. name, NI number, employee number, email address, physical features). It can be factual (e.g. contact details or date of birth), an opinion about an individual’s actions or behaviour, or information that may otherwise impact that individual in a personal or business capacity.
Data protection law divides personal data into two categories: ordinary personal data and special category data. Any personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health conditions, sexual life or sexual orientation, or biometric or genetic data that is used to identify an individual is known as special category data. (The rest is ordinary personal data).
What type of ordinary personal data do we hold about you and why?
At the initial stages of recruitment, we collect, hold and use the following types of ordinary personal data about you:
- Information contained in your application form/CV/covering letter, including your name, title, contact details, photograph, employment history, experience, skills, qualifications/training (including educational, vocational, driving licences where appropriate), referees’ names and contact details, etc.
- Publicly available information about you, such as your business social media presence
- Selection information, including correspondence, interview notes, internal notes, the results of any written or online selection tests
- Pre-employment check information, including references and verification of qualifications
- Right to work checks and related documents
- process your application and correspond with you about it;
- assess whether you have the required skills, experience, qualifications and training for a role within the company;
- make informed recruitment decisions;
- verify information provided by you;
- check and demonstrate that you have the legal right to work in the UK;
- keep appropriate records of our recruitment process and decisions;
Data protection law specifies the legal grounds on which we can hold and use personal data.
We rely on one or more of the following legal grounds when we process your ordinary personal data:
- We need it to take steps at your request in order to enter into a contract with you (entry into a contract), because by applying for a job with us you are effectively asking us to enter into a contract with you [whether this is an employment contract, a contract for services or another type of contract].
- We need it to comply with a legal obligation (legal obligation), e.g. the obligation not to discriminate during our recruitment process, or the obligation not to employ someone who does not have the legal right to work in the UK.
- It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (legitimate interest). For example, it is in our legitimate interests to review and consider your personal data (as listed above) so that we can select the most appropriate candidate for the job.
What type of special category personal data do we hold about you, why, and on what legal grounds?
We will only collect, hold and use limited types of special category data about you during the recruitment process, as described below.
Since special category data is usually more sensitive than ordinary personal data, we need to have an additional legal ground (as well as the legal grounds set out in the section on ordinary personal data, above) to collect, hold and use it. The additional legal grounds that we rely on to collect, hold and use your special category data are explained below for each type of special category data.
At the initial stages of recruitment, we collect, hold and use the following special category data about you:
- the amount, nature, and sensitivity of the personal data
- the risk of harm from unauthorised use or disclosure
- the purposes for which we process your personal data and how long we need the particular data to achieve these purposes
- how long the personal data is likely to remain accurate and up to date
- for how long the personal data might be relevant to possible future legal claims
- any applicable legal, accounting, reporting or regulatory requirements that specify how long certain records must be kept
In all cases, we will not keep your personal data for longer than we need it for our legitimate purposes.
If you give us details of referees, we require you to inform them what personal data of theirs you are giving to us. You must also give them our contact details and let them know that they should contact us if they have any queries about how we will use their personal data.
You have a number of legal rights relating to your personal data, which are outlined here:
- The right to make a subject access request. This enables you to receive certain information about how we use your data, as well as to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- The right to request that we correct incomplete or inaccurate personal data that we hold about you.
- The right to request that we delete or remove personal data that we hold about you 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 data where you have exercised your right to object to processing (see below).
- The right to object to our processing your personal data where we are relying on our legitimate interest (or those of a third party), where we cannot show a compelling reason to continue the processing
- The right to request that we restrict our processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- The right to withdraw your consent to us using your personal data. As described above, we do not normally rely on your consent as the legal ground for using your personal data. However, if we are relying on your consent as the legal ground for using any of your personal data and you withdraw your consent, you also have the right to request that we delete or remove that data, if we do not have another good reason to continue using it.
- The right to request that we transfer your personal data to another party, in respect of data that you have provided where our legal ground for using the data is that it is necessary for the performance of a contract or that you have consented to us using it (this is known as the right to “data portability”).If you would like to exercise any of the above rights, please contact Cat Nicol, HR Manager, HUBER+SUHNER Polatis Ltd, 332 Science Park, Milton Road, Cambridge, CB4 0WN, in writing. Note that these rights are not absolute and in some circumstances we may be entitled to refuse some or all of your request.
If you have any questions or concerns about how your personal data is being used by us, you can contact Cat Nicol, HR Manager, HUBER+SUHNER Polatis Ltd, 332 Science Park, Milton Road, Cambridge, CB4 0WN.
Note too that you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Details of how to contact the ICO can be found on their website: https://ico.org.uk