Recruitment privacy promise

    Recruitment privacy promise

    Complete Care Agency Ltd is registered with the Information Commissioners Office (ICO) under the provisions of the Data Protection Act 1998. The Company takes its responsibilities under the Act very seriously. This notice provides details of how Complete Care Agency collects and uses information about you.

    For more general information about how we use your information, please refer to our Company Website – https://completecareagency.co.uk/

    We ask that you read this Recruitment Privacy Promise carefully, as it contains important information on how and why we collect, store, use and share personal information, your rights in relation to your personal information; and on how to contact us and other organisations in the event you have a complaint.

    You may also be interested in the following;

    Introduction

    In order to identify, select, train and recruit new employees we collect and process personal information about you.

    Personal information means any information about you from which you can be identified, but it does not include information where your identity has been removed (anonymous data).

    As the ‘controller’ of personal information, we are responsible for how that data is managed. The General Data Protection Regulation(GDPR), which applies in the United Kingdom and across the European Union, sets out our obligations to you and your rights in respect of how we manage your personal information.

    As the ‘controller’ of your personal information, we will ensure that the personal information we hold about you is:

    • Used lawfully, fairly and in a transparent way;
    • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
    • Relevant to the purposes we have told you about and limited only to those purposes;
    • Accurate and kept up to date;
    • Kept only as long as necessary for the purposes we have told you about;
    • Kept securely.

    If you have any questions about this privacy promise or would like further explanation as to how your personal information is managed then please contact us. This document provides the information as required by GDPR under your right to be informed.

    Personal data we process

    There are two main ways we collect personal data about you:

    • Directly from you by registering an interest via our website, social media, submitting a CV or registering an interest directly to us, applying for jobs through a third-party website, etc;
    • From third parties such as your referees or third-party sources such as job sites or LinkedIn.

    We will only collect the information that we require at specific times during the recruitment process, such as:

    • Name;
    • Contact details (postal address, phone number, email address);
    • Age / date of birth;
    • Gender;
    • Marital status;
    • Your CV (including education details, employment history);
    • Vehicle registration number;
    • Details of your Right to Work (immigration status);
    • Driving licence number;
    • National Insurance number;
    • Bank details;
    • Proof of identity (passport, driving licence, identity card);
    • Proof of address;
    • Next of kin contact details;
    • Referee contact details;
    • Information collected within interview notes;
    • Photograph;
    • Extra information that you choose to tell us (in writing or verbally);
    • Extra information that your referees choose to tell us about you.

    Certain information that we process is classed as ‘special category data’. This means it is sensitive by nature and we therefore have a higher duty of care in how we process this data:

    • Criminal cautions or convictions;
    • Religion;
    • Nationality or ethnicity;
    • Medical information;
    • Motoring convictions.

    When using our website, we collect standard internet log information (otherwise known as cookies) including:

    • IP address;
    • Details of the pages you visit;
    • General details about the type of computer or device that you are using.

    This is statistical information only which we collect in order to find out the numbers of visitors to our site and the pages they have visited. This information collected in such a way that it is not used to identify individuals. Where we do collect personal information on the website, this will be made obvious to you through the relevant pages. See our full Cookie Policy for more information.

    Please be aware that our website may provide you with links to other websites. If you follow a link to any other website please note they have their own privacy promises. We do not accept any responsibility or liability for the privacy and security practices of such third-party websites and your use as such is at your own risk.

    Whether information has to be provided by you, and if so why

    The provision of certain personal data is necessary to enable us to fulfil our contractual and legal duties as part of the recruitment process. Depending on the type of personal data, and the grounds for which we are processing it, should you decline to provide us with such data we may not be able to fulfil our contractual requirements, and in extreme cases may not be able to continue with our relationship.

    Purposes of processing your personal information

    In order to provide you with the best possible employment opportunities within Complete Care Agency we will process personal data.

    Purpose of ProcessingExamples
    Screening of applicationsTo assess and shortlist candidates as part of the recruitment process for Complete Care Agency (including telephone interviews);
    To review and make informed decisions on the re-employment of a previous employee;
    To receive, process and assess criminal convictions and cautions of candidates as part of the employment process;
    To receive, process and assess details of motoring offences on candidates driving license (UK Only), as part of the screening process.
    Interview and SelectionTo receive, record and process applications for employment with Complete Care Agency;
    To schedule interviews;
    To conduct and record details of interviews with candidate for employment with Complete Care Agency.
    Plan and deliver training during recruitmentTo schedule any required training with candidates as part of the recruitment process;
    To book necessary travel and accommodation for candidates attending the training as part of the recruitment process;
    To confirm that the candidate has successfully passed the required training before continuing with the recruitment process.
    Communicate about the progress of your applicationTo maintain communication with candidates in relation to their ongoing application;
    To process withdrawal requests from candidates or to process rejection notices to candidates.
    To take up referencesTo receive and record contact details for Referees as provided by the candidate;
    To attain and verbally confirm employment and / or character references for employment.
    To keep records to demonstrate our compliance to relevant lawsTo review, verify and take appropriate copies of relevant documentation for the recruitment process.
    To monitor the operational effectiveness of our recruitment processTo monitor and report on the effectiveness and compliance of the recruitment process.
    Sourcing appropriate candidatesTo receive and contact prospective candidates referred to Complete Care Agency by an existing employee to market job opportunities we believe may be of interest;
    To maintain communication with prospective candidates who may have withdrawn or not started to market job opportunities we believe may be of interest;
    To source and contact prospective candidates via third party recruitment platforms to market job opportunities we believe may be of interest.

    Who has access to your personal data

    In order to operate our business and run our recruitment we rely on third parties to provide specialist support to us. To provide this support they will have access to, or a duty of care over your personal information. These third parties are:

    • IT and telecoms support companies – to ensure the safe, secure and resilient operation of our IT infrastructure including computers, servers, phones and mobile devices:
    • Software support companies – to provide specialist support and resolve issues with the software that we run, for example the systems we use to store and manage your recruitment progression:
    • Relevant authorities – such as the DVLA, HMRC;
    • Applicant screening service providers – for checking criminal records;
    • Referees – to confirm character and employment details.

    We will share relevant information within Complete Care Agency during the recruitment process, for example with hiring managers.

    We will not share, sell or trade your personal information with any other third party without your consent, unless there is a legal reason to do so.

    International transfer

    All your personal data is stored and processed on systems that are within the European Economic Area (EEA) and offer the same level of legal protection and rights over your data.

    In certain situations, we transfer your personal information to the following countries;

    • Which are located outside the European Economic Area (EEA);
    • A country where you are resident or located in temporarily;
    • This will be for the purposes of communicating with you about your recruitment process when you are based in a country outside of the EEA;
    • This international transfer is under Article 49(1)(b) – the transfer is necessary for the performance of a contract between the data subject and the controller.

    Such countries do not have the same data protection laws as the United Kingdom and EEA. Any transfer of your personal information will be subject to appropriate or suitable relevant safeguards that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.

    If you would like further information please contact us (How to Contact Us below).

    Retention schedule

    Type of dataRetention Period
    Application details for successful candidatesThis data will become part of your employee file and are retained in line with the information within our employee privacy promise.
    Application details for candidatesThis data is deleted automatically after 18 months from the last date you logged into our careers site, unless deleted earlier at your request. You will have the option of extending this if you choose.
    Details for prospective candidatesThis data will be deleted if we have not had meaningful contact with you for a period of 18 months, unless deleted earlier at your request.

    Legal basis for processing

    We rely on the following grounds within the GDPR:

    • Article 6(1)(b) – processing is necessary for the performance of a contractto which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
    • Article 6(1)(c) – processing is necessary for us to demonstrate compliance with the lawor regulatory frameworks;
    • Article 6(1)(f) – in pursuit of legitimate interests;
    • To review and make informed decisions on the re-employment of a previous employee;
    • To monitor and track the effectiveness and compliance of the recruitment process;
    • To contact prospective candidates to market job opportunities we believe may be of interest;
    • GDPR recognises that additional care is required when processing special category (sensitive) data such as your health, religious views. We process this under the following grounds within GDPR:
    • Article 9(2)(b) – Legal obligationsunder employment or social benefit law

    Your rights

    Under the GDPR you have important rights free of charge. In summary, those include rights to:

    • Fair processing of information and transparency over how we use your use personal information;
    • Access to your personal information and to certain other supplementary information that this Privacy Promise is designed to address;
    • Require us to correct any mistakes in your information which we hold;
    • Require the erasure (i.e. deletion) of personal information concerning you, in certain situations. Please note that if you ask us to delete any of your personal information which we believe is necessary for us to comply with our contractual or legal obligations, this may affect our ability to provide employment or to fulfil our contractual duties with you;
    • Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
    • Object at any time to processing of personal information concerning you for direct marketing;
    • Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
    • Object in certain other situations to our continued processing of your personal information;
    • Otherwise restrict our processing of your personal information in certain circumstances;
    • Claim compensation for damages caused by our breach of any data protection laws.

    For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the GDPR.

    Keeping your personal information secure

    The confidentiality and security of your information is of paramount importance to us. We have appropriate organisational and technical security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it.

    Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

    We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

    If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

    Right to complain

    If at any time you feel that we have failed to safeguard your information appropriately you have the right to complain.  In the first instance we would ask you to contact us and allow us to investigate and identify any issues you have by contacting us below.

    How to complain

    We hope that we can resolve any query or concern you raise about our use of your information. The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at ico.org.uk/concerns/ or by phoning 0303 123 1113.

    How to contact us;

    Online;           https://completecareagency.co.uk/

    Email;             data@completecareagency.com

    Post;              1 Airport West, First Floor, Lancaster Way,Leeds LS19 7ZA

    Telephone;    0333 200 0441

    If you would like to exercise any of those rights, please:

    • Contact us using the details above – making clear that you wish to exercise one of your privacy rights;
    • Let us have enough information to identify you (e.g. your name and address);
    • Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill);
    • Let us know the information to which your request relates, including any account or reference numbers, if you have them.

    If you would like to unsubscribe from our recruitment contact you can either delete your candidate profile on our careers site or contact us, as above, to request to unsubscribe from recruitment contact. It may take up to 14 days for this to take place.

    Review of this Privacy Promise;

    Date:                                       11 March 2019

    This policy will be reviewed every 3 years, or earlier as required.