Job Applicant Privacy Notice

Where is this policy applicable?

This policy applies to companies within the Devenish group based the European Economic Area.
It does not apply to Devenish companies in the US and countries outside of the European Economic Area (EEA), to whom the General Data Protection Regulations (GDPR) do not apply to.

The Devenish group within the EEA, inclusive of all subsidiaries, is referred to as ‘The Company’ in this policy. 

Who does this policy apply to?

As part of any recruitment process the company collects and processes personal data relating to applicants.

The company recruit in a number of ways, eg direct through job adverts on job boards or the company’s websites, via recruitment agencies, though unsolicited applications or through headhunting.

The company recruit for temporary, permanent, placement and fixed-term roles in full and part-time capacity.

This policy applies to applicants during all types of recruitment, referred to as ‘You’ or ‘Your’ in this policy.

Overview

This notice will inform you as to how we look after your personal application related data during and after the recruitment process. It complies with the requirements in accordance with the Data Protection Act 2018 and EU General Data Protection Regulation (EU 2016/679).

What information do we collect?

The company 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, education and employment history
  • Information about your current level of remuneration, including benefit entitlements
  • Whether or not you have a disability for which the organisation 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 disability, religious background or beliefs (this applies only to applicants who apply for roles in Northern Ireland and is collected for legally required reporting purposes) 

We collect this information in a variety of ways. For example, data might be contained in application forms, cover letters, CVs, obtained from your passport or other identity documents, or collected through interviews, or other forms of assessment. Data may be supplied to us directly from you, or via an agency or educational body that is acting on your behalf.

We will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers. We will seek information from third parties only once a job offer to you has been made and will inform you that we are 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 do we process personal data?

Processing your application data allows the company to manage the recruitment process, and assess and confirm your suitability for employment. Should you be successful through the recruitment process we also need to process your data to enter into an employment contract, or services contract, with you.

In some cases, Devenish needs to process data to ensure that it is complying with its legal obligations. For example, the company is required to check a successful applicant's eligibility to work in the UK before employment starts. Devenish has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. We may also need to process data from job applicants to respond to and defend against potential legal claims.

Devenish 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 we process other special categories of data, such as information about disability, religious background or beliefs, this is for equal opportunities monitoring purposes as permitted by the Data Protection Act 2018 (NI). This only applies to applicants who apply for roles based in Northern Ireland.

Devenish will not use your data for any purpose other than the recruitment exercise for which you have applied. However, if your application is unsuccessful, we may keep your personal data on file for our records, and in case there are future employment opportunities for which you may be suited.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise with members of the HR team, and/or, managers, interviewers and stakeholders involved in your recruitment process. Your data may also be shared externally with assessors involved in your recruitment process who are not the company’s direct employees.

As part of the recruitment process the company may also share your data with third parties, eg for a ‘pre-employment’ health checks, pre-employment assessments such as verbal or numerical reasoning assessments or occupational personality questionnaires. Your data may also be shared with IT staff unconnected to the recruitment process, if access to the data is necessary for the performance of their roles. Devenish may share your data with former employers to obtain references for you, or with employment background check providers to obtain necessary background checks. Employment decisions are not based solely on automated decision making.

As we operate globally, your data may be transferred outside the European Economic Area (EEA) to USA or other locations where we have operations. Data is transferred outside the EEA on the basis of all relevant safeguards eg compliance with DPA and EU GDPR (EU) 2016/679.

How does the organisation protect data? 

Devenish 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. If you would like further information on how your information is protected email privacy@Devenish.com.

How long does the organisation keep data for?

If your application for employment with Devenish is unsuccessful, after the end of the relevant recruitment process the company will keep your recruitment data for its records, or for consideration of future employment opportunities, for up to 12 months. After 12 months the company will delete/destroy the data if no further recruitment exercise is underway.

Providing your data

You are under no statutory or contractual obligation to provide data to Devenish 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. 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.

Your rights

You are entitled to:

  • Access and obtain a copy of your data on request
  • Request the company to change incorrect or incomplete data
  • Request Devenish to delete or stop processing your data (eg when data is no longer necessary for processing purposes)
  • Object to the processing of your data where Devenish is relying on “legitimate interest” or “consent” as the legal basis for processing
  • Request Devenish to stop processing data for a period if data is inaccurate or there is a dispute about whether your interests override the Company’s legitimate grounds for processing data

Where Devenish relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of job applicants, employees or workers and has concluded that they are not

If you would like to access any of these rights, have any queries or require further information, please email your request to privacy@devenish.com

If you believe that Devenish has not complied with your data protection rights, you can complain to the Information Commissioners office - www.ico.org

Board Authorised: 19.03.19 Ver 1.0