Recruitment GDPR

Contents

1. Introduction
2. What information does Whitecode Group collect?
3. Why does Whitecode Group process personal data?
4. Who has access to data?
5. How does Whitecode Group protect data?
6. For how long does Whitecode Group keep data?
7. Your rights
8. What if you do not provide personal data?
9. Automated decision-making

1. Introduction

Data controller:
Whitecode Group, Highfield House, 2-4 West Hill, Dartford DA1 2EW
01322 289977
Data protection officer:
HR Manager
Email: HR@whitecode.co.uk
01322289977

As part of any recruitment process, Whitecode Group collects and processes personal data relating to job applicants. Whitecode Group is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

This Policy covers all areas of Whitecode Group and subsidiary businesses:
• Whitecode Design Associates Ltd
• Whitecode Developments Ltd
• Walker Mower Partnership Ltd
• Vitech Services Ltd

2. What information does Whitecode Group collect?

Whitecode Group collects a range of information about you. This includes:
• 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 or not you have a disability for which Whitecode Group needs to make reasonable adjustments during the recruitment process
• information about your entitlement to work in the UK
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief

Whitecode Group collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment including online tests.

Whitecode Group 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 (where appropriate)

Whitecode Group 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).

3. Why does Whitecode Group process personal data?

Whitecode Group 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, Whitecode Group 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.

Whitecode Group 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 Whitecode Group to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. Whitecode Group may also need to process data from job applicants to respond to and defend against legal claims.

Whitecode Group 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.

Whitecode Group processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

For some roles, Whitecode Group is obliged to seek information about criminal convictions and offences. Where Whitecode Group 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.

If your application is unsuccessful, Whitecode Group will keep your personal data on file in case there are future employment opportunities for which you may be suited. Whitecode Group will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

4. Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes HR and the 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.

Whitecode Group will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Whitecode Group 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 (if appropriate).

Whitecode Group will not transfer your data outside the European Economic Area.

5. How does Whitecode Group protect data?

Whitecode Group 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. Your data is held on a Whitecode internal server and access is limited to relevant parties via a password protected log in.

6. For how long does Whitecode Group keep data?

If your application for employment is unsuccessful, Whitecode Group will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow Whitecode Group to keep your personal data on file, Whitecode Group 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 will be provided to you in a new privacy notice.

7. Your rights

As a data subject, you have a number of rights. You can:
• access and obtain a copy of your data on request;
• require Whitecode Group to change incorrect or incomplete data;
• require Whitecode Group 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 Whitecode Group is relying on its legitimate interests as the legal ground for processing; and
• ask Whitecode Group to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override Whitecode Group’s legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact HR@whitecode.co.uk or by post to HR at Whitecode Group, Highfield House, 2-4 West Hill, Dartford DA1 2EW.

You can make a subject access request by emailing your request to HR using the above contact details.

If you believe that Whitecode Group has not complied with your data protection rights, you can complain to the Information Commissioner.

8. What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Whitecode Group during the recruitment process. However, if you do not provide the information, Whitecode Group may not be able to process your application properly or at all.

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.

9. Automated decision-making

Whitecode Group recruitment processes are not based solely on automated decision-making.

Leave a comment