Data Protection Privacy Notice (Recruitment)

This notice explains what personal data (information) we collect and hold about you and how we will use and may share information about you during the application process.

 

Who collects the information?

Circadian Trust gathers and uses certain information about you. Under data protection law we are regarded as a ‘data controller’. We comply with data protection laws when gathering and using your personal information.

 

The information we collect

We collect the following information up to and including the shortlisting stage of the recruitment process:

• Your name and contact details (i.e. address, home and mobile phone numbers, email address);
• Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests;
• Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs;
• Information regarding your criminal record (if applicable);
• Details of your referees.

We also collect equality, diversity and inclusion (EDI) information, which may include race or ethnicity, religious beliefs and sexual orientation to comply with our legal obligations and for equal opportunities monitoring. However, this EDI information is aggregated together and held anonymously; it is not linked to your own personal information and cannot be viewed by anyone associated with our recruitment processes.

 

We may collect the following information after the shortlisting stage, and before making a final decision to recruit:

• Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers *;
• Information regarding your academic and professional qualifications *;
• Information regarding your criminal record, in criminal records certificates (CRCs) and enhanced criminal records certificates (ECRCs) *;
• Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information *;
• A copy of your driving licence *.

You are required to provide the categories of information marked ‘*’ above to us to enable us to verify your right to work and suitability for the position. By law or in order to enter into your contract of employment

 

How we collect this information

We may collect information directly from you directly or via a recruitment agent, from your referees (details of whom you will have provided), your education provider, the relevant professional body, the Disclosure and Barring Service (DBS) and the Home Office.

 

How we use your personal information

The following table sets out the purposes for which we collect and use personal information. We make sure we have a lawful basis for our recruitment activities, as stated below. We’ve included where we rely on the lawful basis of legitimate interests.

Purpose	Lawful Basis
To handle job applications and to evaluate suitability for the role(s)	To perform necessary activities with respect to the prospect of entering into an employment contract
To ensure equal opportunities	Legal obligation; legitimate interests
Employment checks, e.g. right to work, DBS	Legal obligation where applicable
Medical assessment when onboarding new staff	Contract; with your consent
To proceed to employment with selected applicants	To take necessary steps when entering into an employment contract
To retain certain data on unsuccessful applicants for 12 months in case another suitable role becomes vacant	With your consent

We seek to ensure that our information collection and processing is always proportionate. We do not carry out any automated decision making in our recruitment processes.

 

Sharing personal data

We may need to share certain personal information with other parties, such as HR consultants and professional advisers. In most situations this information will be anonymised, but this may not always be possible. Recipient of personal information are bound by a contract which includes confidentiality obligations.

 

We use external service providers to support the efficient running of our business, including our recruitment processes. These providers handle personal data on our behalf, and we have appropriate contractual arrangements in place to cover these relationships. Where a service provider is located based outside the UK, the transfer of personal information is covered by appropriate legal safeguards.

 

We may be required to disclose certain personal information to comply with the law, such as to carry out employment checks. If you attend one of our centres for interview you should be aware we have CCTV in operation in some locations. In the event of an incident on site, the CCTV footage maybe shared with the Police or other statutory bodies.

 

Sensitive personal information and criminal records information

Further details on how we handle sensitive personal information and information relating to criminal convictions and offences are set out in our Disclosure and Barring Service (DBS) Policy, available from the HR department at HRinbox@circadiantrust.org.

 

How long we keep your information

We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.

 

We keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping certain recruitment records for longer than the recruitment period, we may do so after considering whether the records can be minimised and the additional period for which they need to be kept.

If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment. We provide new employees with a copy of our Employee Privacy Notice.

If your application is unsuccessful, you may be provided a choice if you’d like us to hold your information on file for 12 months in case another suitable role becomes vacant.

 

Your personal information rights
You have a number of rights under UK data protection laws:

• Informed: You have the right to be informed about how we handle your personal data.  This privacy notice is one of the ways we do this.
• Access: You have the right to ask for a copy of the personal data we hold about you and the purposes for which we are using it.
• Rectification: You have the right to ask us to change any personal details which are incorrect and need updating.
• Erasure: You have the right to ask us to erase your personal details. We will assess any deletion request on a case-by-case basis and in some cases, we may refuse requests to erase your details.
• Object: You have the absolute right to object to receiving direct marketing communications from us.
• Restriction: You have the right to ask us to restrict or suppress your personal information. This would mean we’d store it but not use it.
• Portability: You have the right to obtain and reuse your personal data for your own purposes across different services.

If you’d like to exercise any of these rights or have any other query, please contact us using the contact details at the top of the page.

 

Keeping your personal information secure

We are committed to handling personal information in accordance with the principles and practices of UK data protection laws. We are committed to keeping your information secure at all times. We maintain appropriate physical, electronic and operational measures to protect the information we hold and prevent any unauthorised access or disclosure.

 

How to raise a complaint

If you believe the way in which we’ve handled your personal information may have infringed data protection law, you can raise a formal complaint using the contact details provided above. Please provide as much information as possible about the nature of your complaint and the outcome you’re seeking. We’ll acknowledge we’ve received your complaint as soon as possible and aim to provide a full response within 30 days. Should a complaint require a more detailed investigation, we’ll let you know within 30 days when you can expect a response from us.

 

In most cases, the Information Commission Office (ICO) is likely to expect you to go through our own complaints process first. If you’re unhappy with our response, you can raise a complaint with the ICO.