Applicant privacy notice

INTRODUCTION

As part of any recruitment process, the Jon Egging Trust (‘JET’) collects and processes personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.

WHO ARE WE?

The Jon Egging Trust is a registered charity in England and Wales (1156265) and Scotland (SC048666) and a company limited by guarantee (8908969). We are also registered with the Information Commissioner’s Officer (ICO) ZA456145. Our registered address is

Highdown House
11 Highdown Road
Leamington Spa
Warwickshire
CV31 1XT

WHAT INFORMATION DO WE COLLECT?

We collect and process 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
• Whether or not you have a disability for which JET needs to make reasonable adjustments during the recruitment process
• Information about your entitlement to work in the UK

DBS check

If your application is successful and where appropriate for the role, we will ask you to apply for a DBS (Disclosure and Barring Service) check. If there are no offences listed, we will receive a snapshot of the certificate directly from the DBS. If there are offences recorded, we will only receive an email from the DBS that offences have been recorded and we will ask you to share a copy of the certificate you have received with us.

Equal Opportunities

During the application process, you are also given a link to complete an anonymous online survey to collect equal opportunities monitoring information, including information about your age, gender, ethnic origin, sexual orientation, religion and health. This data is processed by our external HR consultants, HR Services Partnership Ltd.

HOW DO WE COLLECT INFORMATION FROM YOU?

We collect information from CVs, covering letters, application forms, your passport or other identity documents and through responses to interview questions.

We will also collect personal data about you from third parties – references are always sought, and a DBS check may be required depending on the nature of the role. Where a DBS is applicable, this will be stated in the job description. We will seek information from third parties only once a job offer to you has been made and we will inform you that we are doing so.

WHERE DO WE STORE YOUR DATA?

Data is stored on our email and IT systems on servers based inside the European Economic Area (EEA). We do not keep paper copies.

WHY DO WE PROCESS PERSONAL DATA?

JET 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 us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.

Where JET relies on legitimate interests as a reason for processing data, we have considered whether those interests are overridden by the rights and freedoms of employees or workers and have concluded that they are not.

We need to process data to ensure that we are complying with our legal obligations.

We are required to check a successful applicant’s eligibility to work in the UK before employment starts. We will process your personal data to ensure that we fulfil our legal obligations in this area. We take a copy of passports or other right to work documents at interview.

For some roles, we are obliged to seek information about criminal convictions and offences. Where JET seeks this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.

We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to the Equalities Act 2010. As this is Special Category Data, the additional lawful basis for processing this is that the processing is necessary for the purposes of preventative or occupational medicine, for the assessment for the working capacity of the employee.

Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion, this is for equal opportunities monitoring and is collected anonymously.

We may also need to process data from job applicants to respond to and defend against legal claims.

We will not use your data for any purpose other than the recruitment exercise for which you have applied.

WHO HAS ACCESS TO YOUR DATA?

Your information will be shared internally for the purposes of the recruitment exercise with our administrator, managers in the team with the vacancy and interviewers involved in the recruitment process.

If our external HR consultants (HR Services Partnership Ltd) are supporting us on the recruitment campaign, your information will be shared with them. If your application for employment is successful and we make you an offer of employment, JET will then share your data with former employers to obtain references for you.

Our IT support is provided by an external contractor (Rejuvenate) with whom we have Data Protection Agreement in place. They have access to our system only under staff supervision and with prior consent and only when it is necessary to troubleshoot IT operating problems. They have no direct or unsupervised access to personal data.

We do not share any data with third parties.

HOW DO WE PROTECT YOUR DATA?

We have 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 authorised employees in the performance of their duties. We also have appropriate technical measures in place to ensure the security of your data.

We do not engage third parties to process personal data on our behalf.

HOW LONG DO WE KEEP YOUR DATA?

If your application for employment is unsuccessful, the copy of your passport or other identity document(s) are destroyed once an offer has been made to and accepted by another applicant. We will hold your application data on file for four months after the start date for the role. At the end of that period or if you object sooner, your data is securely 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.

YOUR RIGHTS

Under data protection legislation you have a number of right. You can:
• Access and obtain a copy of your data on request (subject access request)
• Require JET to change incorrect or incomplete data
• Require JET 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 JET is relying on its legitimate interests as the legal ground for processing
• Ask JET to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override JET’s legitimate grounds for processing data
• Complain to the ICO

If you would like to exercise any of these rights, please contact our data protection lead:

Email: info@joneggingtrust.org.uk
Telephone: 0300 123 3044
Post: The Jon Egging Trust, PO Box 17617, Redditch B97 9RU

If you have a concern or complaint about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office at https://ico.org.uk/concerns/

WHAT IF YOU DO NOT PROVIDE PERSONAL DATA?

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

AUTOMATED DECISION-MAKING

Our recruitment processes are not based on automated decision-making.

This policy was last updated on 25/02/2019