Candidate Privacy Notice
Data controller: Ancala Water Services (Defence) Limited, Unit 1B, Redbrook Business Park, Wilthorpe Road, Barnsley, S75 1JN.
We are registered as a data controller and our registration can be viewed online in the public register at: https://ico.org.uk/about-the-ico/what-we-do/register-of-fee-payers/.
Data protection officer: Sean Ratcliffe, Quality Assurance Manager, GDPR@ancalawater.com
As part of any recruitment process, the organisation collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data, and the lawful bases for doing so, in accordance with the General Data Protection Regulation (GDPR).
WHAT INFORMATION DOES THE ORGANISATION COLLECT?
The organisation collects a range of information about you. This includes, but may not be limited to, the following:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- whether you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process; and
- information about your entitlement to work in the UK.
The organisation collects this information in a variety of ways. For example, data might be contained in application forms, CVs and covering letters; be obtained from your passport or other identity documents; or collected through interviews or other forms of assessment, including online tests.
The organisation will 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. The organisation 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 HR management systems and on other IT systems, including email.
WHY DOES THE ORGANISATION PROCESS PERSONAL DATA?
The organisation needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
The organisation has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.
Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether those interests are overridden by the rights and freedoms of job applicants, employees or workers and has concluded that they are not.
The organisation processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where the organisation processes special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes and even greater care and attention is given to personal data falling within the GDPR’s ‘special categories’ (previously referred to under the DPA as sensitive personal data).
For some roles, the organisation is obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment to establish whether an individual has committed an unlawful act or been involved in dishonesty or other improper conduct.
If your application is unsuccessful, the organisation will keep your personal data on file in case there are future employment opportunities for which you may be suited. The organisation will ask for your consent before it keeps your data for this purpose, and you are free to withdraw your consent at any time by contacting GDPR@ancalawater.com.
WHO HAS ACCESS TO DATA?
Your information will be shared internally for the purposes of the recruitment exercise. 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.
Your data will also be shared with our approved third-party data processor who is involved in the recruitment process. Data is handled in accordance with the organisation’s privacy policies and in accordance with all relevant GDPR laws.
If your application for employment is successful and an offer of employment is made, the organisation will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
The organisation will not transfer your data outside the UK.
HOW DOES THE ORGANISATION PROTECT DATA?
The organisation takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused, or disclosed, and is not accessed except by our employees in the proper performance of their duties.
Controls measures are regularly monitored and tested to ensure they are adequate, effective, and compliant at all times. Data minimisation methods are frequently reviewed, and new technologies assessed to ensure that we are protecting data and individuals to the best of our ability.
Regular testing of the company IT systems is undertaken, this includes security and access restriction checks along with vulnerability scanning and penetration testing of our networks.
FOR HOW LONG DOES THE ORGANISATION KEEP DATA?
If your application for employment is unsuccessful, the organisation will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow the organisation to keep your personal data on file, the organisation will hold your data on file for a further 6 months for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data is deleted 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. The periods for which your data will be held can be found in our data retention policy.
YOUR RIGHTS
As a data subject, you have a number of rights, including:
- access and obtain a copy of your data on request.
- require the organisation to change incorrect or incomplete data.
- require the organisation 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 the organisation is relying on its legitimate interests as the legal ground for processing; and
- ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether your interests override the organisation’s legitimate grounds for processing data.
Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception, we will explain this to you in our response to your request.
Should you wish to contact us with regard to any of the rights allowed to you under the GDPR please contact us by email to GDPR@ancalawater.com using the subject line Subject Access Request or by post, marking your letter for the attention of The Data Controller at:
Ancala Water Services (Defence) Limited, Unit 1B, Redbrook Business Park, Wilthorpe Road, Barnsley, S75 1JN
If you believe that the organisation has not complied with your data protection rights, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office at: https://ico.org.uk/make-a-complaint.
WHAT IF YOU DO NOT PROVIDE PERSONAL DATA?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all. If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the UK and satisfactory references.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.
AUTOMATED DECISION-MAKING
Recruitment processes are not based solely on automated decision-making.