Privacy Policy: Recruitment
INTRODUCTION
This notice explains how the OpenPayd (referred to in this notice as
we, us or our) collects and uses personal data during the recruitment
and selection process. This notice covers the following:
WHAT IS THE LEGAL BASIS THAT PERMITS US TO USE YOUR PERSONAL DATA?
WHAT HAPPENS IF YOU DO NOT PROVIDE THE PERSONAL DATA THAT WE REQUEST?
The Table at the end of this notice provides an overview of the
personal data that we collect, the purposes for which we use that data,
the legal basis which permits us to use it and the rights that you have
in relation to your personal data.
We may update this notice from time to time.
CONTACT DETAILS
Contact: People Team
Address: The Tower at the Bower, 207-211 Old Street London, EC1V 9NR
Email: [email protected]
1. WHAT IS PERSONAL DATA
Personal data is any information that tells us something about you.
This could include information such as your name, contact details, date
of birth, and references.
2. HOW DO WE COLLECT PERSONAL DATA
We collect personal data about you from various sources including:
• From you when you contact us directly through the application and recruitment process
• From other people when we check references or carry out background
checks – if we do this we will inform you during the recruitment process
of the exact checks that are carried out.
3. WHAT PERSONAL DATA DO WE COLLECT?
• Personal contact details such as name, title, address, telephone number and personal email addresses
• Date of birth
• Equal opportunities monitoring information such as gender, race, ethnicity, religion, health and sexual orientation
• Recruitment information (including copies of right to work
documentation, qualifications, references and other information in your
CV or cover letter or otherwise provided as part of the application
process)
• Information about criminal convictions and offences committed by you
4. HOW WE USE YOUR PERSONAL DATA
We use your personal data for the following purposes:
• To make decisions about your recruitment and appointment
• To check you are legally entitled to work in the country where the job is located
• To assess your qualifications for a particular job or task
• To conduct data analytics studies to review and better understand
job application rate and to conduct candidate experience analytics to
review and better understand candidate interview experience
• To carry out equal opportunities monitoring
• For fraud and crime prevention purposes
• To deal with legal disputes
We do not take automated decisions about you using your personal data or use profiling in relation to you.
5. WHAT IS THE LEGAL BASIS THAT PERMITS US TO USE YOUR PERSONAL DATA?
Under data protection legislation we are only permitted to use your
personal data if we have a legal basis for doing so as set out in the
data protection legislation. We rely on the following legal bases to use
your personal data for employment/engagement related purposes:
• Where we need your personal data to enter into a contract with you.
• Where we need to comply with legal obligation
• Where it is necessary for our legitimate interests (or those of a
third party) and your interests and fundamental rights do not override
those interests.
The Table at the end of this notice provides more detail about the
personal data that we use, the legal basis that we rely on in each case
and your rights.
Some personal data is classified as "special" data under data
protection legislation. This includes information relating to health,
racial or ethnic origin, religious or philosophical beliefs, sex life,
political opinions, biometric data, genetic data, sexual orientation and
trade union membership. This personal data is more sensitive and we
need to have further justifications for collecting, storing and using
this type of personal data. There are also additional restrictions on
the circumstances in which we are permitted to collect and use criminal
conviction data. We may process special categories of personal data and
criminal conviction information in the following circumstances:
• In limited circumstances with your explicit consent, in which case
we will explain the purpose for which the personal data will be used at
the point where we ask for your consent.
• We will use information about your physical and mental health or
disability status to comply with our legal obligations, including to
ensure your health and safety in the workplace.
• We will use information about your race or ethnic origin, religious
or philosophical beliefs, your sexual life or sexual orientation to
ensure meaningful equal opportunity monitoring and reporting – the legal
basis of this processing is that it is in the public interests to carry
out diversity monitoring.
6. WHAT HAPPENS IF YOU DO NOT PROVIDE THE PERSONAL DATA THAT WE REQUEST?
We need some of your personal data in order to conduct the
recruitment and selection process. If you do not provide such personal
data, we may not be able to continue with the recruitment process or
offer you employment/engagement. We explain when this is the case at the
point where we collect personal data from you.
7. HOW DO WE SHARE YOUR PERSONAL DATA?
We share your personal data in the following ways:
• Where we use third party services providers who process personal
data on our behalf in order to provide services to us. This includes
recruitment agents and IT systems providers.
• We will share your personal data with third parties where we are
required to do so by law or to comply with our regulatory obligations.
• With other entities in our group as part of our regular reporting
activities and in the context of a business reorganisation or group
restructuring exercise.
• If we sell any part of our business and/or integrate it with
another organisation your details may be disclosed to our advisers and
to prospective purchasers or joint venture partners and their advisers.
Where we share your personal data with third parties we ensure that
we have appropriate measures in place to safeguard your personal data
and to ensure that it is solely used for legitimate purposes in line
with this privacy notice.
8. HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
Information is only stored on company central file share and
recruitment information systems which are restricted through the use of
access rights and controlled on a need to know basis.
We will ensure access to personal data is restricted to employees
working within our group on a need to know basis. Training will be
provided to any employees working within the group who need access to
your personal data to ensure it is secured at all times.
9. WHEN DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE UK AND EUROPEAN ECONOMIC AREA?
When personal data is transferred to countries outside of the UK and
the European Economic Area those countries may not offer an equivalent
level of protection for personal data to the laws in the UK. Where this
is the case we will ensure that appropriate safeguards are put in place
to protect your personal data.
[We will not send your personal data outside of the European Economic
Area, unless you apply for a job at our office in Turkey, in which case
your personal data will be shared with local HR and the hiring
manager(s) for the purpose of progressing your application.]
10. FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?
As a general rule we keep personal data about candidates for the
duration of the recruitment and selection process and for a period of 3
years after candidates have been notified whether their application has
been successful. However, where we have statutory obligations to keep
personal data for a longer period or where we may need your personal
data for a longer period in case of a legal claim, then the retention
period may be longer.
11. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
You have a number of rights in relation to your personal data, these include the right to:
(a) Be informed about how we use your personal data
(b) Obtain access to your personal data that we hold
(c) Request that your personal data is corrected if you believe it is incorrect, incomplete or inaccurate;
(d) Request that we erase your personal data in the following circumstances: (i) if we are continuing to process personal data beyond the period when it is necessary to do so for the purpose for which it was originally collected
(ii) If we are relying on consent as the legal basis for processing and you withdraw consent
(iii) If we are relying on legitimate interest as the legal basis
for processing and you object to this processing and there is no
overriding compelling ground which enables us to continue with the
processing(iv) If the personal data has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
(e) Ask us to restrict our data processing activities where you consider that: (i) personal data is inaccurate
(ii) Our processing of your personal data is unlawful
(iii) Where we no longer need the personal data but you require us
to keep it to enable you to establish, exercise or defend a legal claim(iv) Where you have raised an objection to our use of your personal data
(f) Request a copy of certain personal data that you have provided
to us in a commonly used electronic format. This right relates to
personal data that you have provided to us that we need in order to take
steps to enter into a contract with you and personal data where we are
relying on consent to process your personal data(g) Object to our processing of your personal data where we are
relying on legitimate interests or exercise of a public interest task to
make the processing lawful. If you raise an objection we will carry out
an assessment to determine whether we have an overriding legitimate
ground which entitles us to continue to process your personal data(h) Not be subject to automated decisions which produce legal
effects or which could have a similarly significant effect on you.(v) If it is necessary to delete the personal data to comply with a legal obligation.
If you would like to exercise any of your rights or find out more, please contact [email protected].
The table at the end of this notice provides more detail about the
personal data that we use, the legal basis that we rely on in each case
and your rights.
12. COMPLAINTS
If you have any complaints about the way we use your personal data please contact People Team at [email protected]
who will try to resolve the issue. If we cannot resolve your complaint,
you have the right to complain to the data protection authority in your
country (the Information Commissioner's Office in the UK).
Table: quick check of how we use your personal data
Purpose
Personal data used
Legal basis
Which rights apply?*
Recruitment decisions including assessment of qualifications
Personal contact details, national insurance number, recruitment information including qualifications, references and other information in your CV or cover letter or otherwise provided as part of the application process, employment/ engagement records,
compensation history, identification documents such as your passport or driving licence.
Legitimate interests. It is in our legitimate interests to evaluate whether you have the necessary skills and qualities to perform the relevant role.
The generally applicable rights plus the right to object.
Right to work checks
Information relating to your right to work status, national insurance number, passport number, nationality, tax status information, and personal contact details.
Legitimate interest. It is in our interests to ensure that those who work for us have the right to work in the UK as well as to establish the statutory excuse to avoid liability for the
civil penalty for employing someone without the right to undertake the
work for which they are employed.
The generally applicable rights plus the right to object.
Fraud and crime prevention
Information about criminal convictions and offences committed by you. Identity verification information.
Public interest and legitimate interest. It is in our interests as well as the interest of our candidates/ employees/ workers/ contractors to ensure the prevention of fraud and
The generally applicable rights plus the right to object.
crime is monitored. This will ensure a safe workplace for all.
Diversity monitoring
Gender, marital status and dependents and information about your race or ethnicity, religious beliefs, health and
sexual orientation.
Public interest.
The generally applicable rights plus the right to object.
To deal with legal disputes
Personal contact details, recruitment information including qualifications, references and other information in your CV or cover letter or otherwise provided as part of the application process, information submitted as part of the selection process and interview
notes.
Legitimate interest. It is in our interests to process personal data to make and defend legal claims to ensure that our legal rights are protected.
The generally applicable rights plus the right to object.
*The following generally applicable rights always apply: right to be informed, right of access, right to rectification, right to erasure, right to restriction and rights in relation to automated decision making. For more detail about your rights and how to exercise them
please see Your rights in relation to your personal data
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