The Growth Company
Applicant Privacy Statement
The references throughout this notice to ‘The Growth Company’ and ‘we’ are references to The Growth Company Limited and its group companies (which are described here).
WHAT IS THE PURPOSE OF THIS DOCUMENT?
The Growth Company is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during the application process, in accordance with the UK General Data Protection Regulation (UK GDPR).
It applies to all applicants.
The Growth Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to any individual who makes an application for employment. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time and will provide you with a copy if you are part of an active recruitment process. If you receive an offer of employment, you will receive new privacy information about how we look after your personal data as an employee at this point.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
This document provides information in relation to the following;
- Data Protection Principles
- Kind of information we hold about you
- How your personal information is collected
- How we will use the information we have collected about you
- What happens if you fail to provide information or if there is a change to the purpose in which we collected the information for
- How we will use sensitive personal information
- Do we need your consent?
- Information about criminal convictions
- Automated decision making
- Data Sharing
- Data Security
- Data retention
- Right of access, correction, erasure and restriction
- Right to withdraw your consent
- Data Protection Officer
- Changes to this notice
DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter.
- The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, education history, employment history, working hours, salary information, qualifications, training records and professional memberships.
- Any information you provide to us during an interview, including psychometric testing and assessment centre outcomes.
- Information relating to right to work in the UK documentation
- Details of referees
We may also collect, store and use the following “special categories” of more sensitive personal information:
- Equal Opportunities. Monitoring Information about your race or ethnicity, religious beliefs, gender, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information relating to criminal convictions and offences.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about applicants through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies including information from criminal records checks.
Information sought from third parties will only be requested once a job offer to you has been made and we will inform you that we are doing so, other than where your application is being submitted via an employment agency.
Data will be stored in a range of different places, including on your application record, in HR systems and on other IT systems including email.
HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to.
We need all the categories of information in the list above (see The kind of information we hold about you) primarily to allow us to determine if it is in our legitimate interest to decide whether it is beneficial to our business to appoint you to the role (*), to enable us to comply with legal obligations (**) or to process data where we need to take steps prior to entering into a contract with you (***). The situations in which we will process your personal information are listed below. If you need more information on the lawful reason for processing your personal data, this can be obtained from the HR department.
- Communicate with you about the recruitment process *
- Making a decision about your recruitment or appointment *
- Determining the terms on which you work for us ***
- Checking you are legally entitled to work in the UK **
- Assessing qualifications for a particular job or task*
- Assessing or identifying education, training and development requirements *
- Dealing with legal disputes involving you, or other employees, workers and contractors **
- Complying with health and safety obligations and other legal or regulatory requirements**
- Conducting data analytics studies to review and better understand employee retention and attrition rates *
- Informing you of other vacancies within the company, where you have consented to this *.
- Keeping records of our hiring process *
- Carrying out background and reference checks **
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
When you submit your application, you can consent within the candidate menu on our careers portal to be alerted about any upcoming vacancies posted by us. We will keep your personal data on file in line with our retention and destruction policy, this being 12 months from the point of your submitted application. You are free to withdraw your consent to this at any time by deactivating your account within the candidate menu on our careers portal (This option is available under ‘Change my password’ field). Please note that once you deactivate your account you will not receive any job alerts from us.
If you fail to provide personal information
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further. We may also be prevented from complying with our legal obligations (such as to ensure the health and safety of our applicants and employees).
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.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information (as described in ‘The kind of information we hold about you’ section above) in the following circumstances:
- We will use information about your disability status, or health, including any medical condition, health and sickness records, where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards, and to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview, assessment centre or test.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting in the public interest.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your vital interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process information about applicants during the course of legitimate business activities with the appropriate safeguards.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law or in the public interest. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data or to retain your data on file to be informed of other vacancies within the organisation. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
INFORMATION ABOUT CRIMINAL CONVICTIONS
For some roles, we are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary to carry out our obligations and exercise specific rights in relation to employment. We will only do this at the point we offer you a role, at which time you will be issued with the employee privacy notice which will contain the information you need to know regarding criminal convictions and offences.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We may have to share your data with third parties, including third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where we have a legitimate interest in doing so. Your information will also be shared internally.
When might you share my personal information with other entities in the group?
We will share your personal information with other entities in our group for the purposes of the recruitment exercise to help determine the suitability of your employment for the role in which you have applied, as part of our regular reporting activities on company performance and reporting; for system maintenance support; corporate services and hosting of data. As part of this, personal information may be shared with interviewers from different parts of our group 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.
Which third-party service providers process my personal information?
”Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities in relation to the application process are carried out by third-party service providers: maintenance of our HR and payroll system, completing pre-employment checks and testing, in determining your suitability for employment.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to appoint you to role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way.
Where you have consented to us informing you of future vacancies, we will retain your data for 12 months from the point you submitted your original application.
After this period, we will securely destroy your personal information in accordance with our data retention policy.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain and securely destroy your personal information in accordance with our data retention and disposal policy.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during and after your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the application process, or in the 12 months following your application if you have consented to be informed of other vacancies.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
DATA PROTECTION OFFICER
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO, (DPOfficer@growthco.uk ). You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the HR Department HRServiceDesk@growthco.uk