Campden BRI Privacy policy for job applicants

This Policy sets out what personal data we, Campden BRI, hold about you and how we collect and use it during and after the recruitment process. It applies to anyone who is applying to work for us, whether as an employee, worker, contractor, consultant, intern, volunteer, placement or work experience student (together referred to as Job Applicant’ or ‘you’).

Introduction

We will not necessarily hold, use or share all of the types of personal data described in this Privacy Notice in relation to you.

The specific types of information about you that we will hold, use and share will depend on the role for which you are applying, the nature of the recruitment process, how far you progress in the recruitment process and your individual circumstances.

We are required by data protection law to give you the information in this Privacy Notice. It is important that you read the Privacy Notice, together with any additional information that we might give you from time to time about how we collect and use your personal data. Should your application be successful, when you start work for us, we will provide you with the Campden BRI Data Protection policy that explains how we deal with your personal data whilst you are working for us.

This Privacy Notice does not give you any contractual rights and may be updated by us at any time.

Who is the controller?

For applicants who have applied direct to Campden BRI, Campden BRI is the data controller of the personal information we collect from and about you.

For applicants who have applied indirectly (e.g. via a recruitment agency) the agency is the data controller of the personal information they collect from and about you until this data is shared with Campden BRI and you are invited to attend interview. At this point Campden BRI becomes the data controller.

What is personal data?

Personal data - any information relating to a data subject which allows the data subject to be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
It can be factual (e.g. contact details or date of birth), an opinion about an individual’s actions or behaviour, or information that may otherwise impact that individual in a personal or business capacity.

Special categories of personal data - biometric and genetic data; information as to racial or ethnic origins; political, religious or other opinions/beliefs of a similar nature; physical or mental health; sexual life; criminal offences or alleged criminal offences and past sentences; and whether he/she is a member of a trade union.

What type of ordinary personal data do we hold about you and why?

At the initial stages of recruitment, we collect, hold and use the following types of ordinary personal data about you:

• Information contained in your application form/CV/covering letter, including your name, title, contact details, employment history, experience, skills, qualifications/training (including educational, vocational, driving licences where appropriate), etc.
• Publicly available information about you, such as your social media presence.
• Selection information, including correspondence, interview notes, internal notes, the results of any written or online selection tests.

If you are shortlisted for a position, or you receive a conditional offer of employment, we may collect, hold and use the following additional types of ordinary personal data about you:

• Process your application and correspond with you about it;
• Assess whether you have the required skills, experience, qualifications and training for the role;

We hold and use this personal data so that we can:

• Process your application and correspond with you about it;
• Assess whether you have the required skills, experience, qualifications and training for the role;
• Make informed recruitment decisions;
• Verify information provided by you;
• Check and demonstrate that you have the legal right to work in the UK;
• Keep records of our recruitment process and decisions.

What are our legal grounds for using your ordinary personal data?

We rely on one or more of the following legal grounds when we process your ordinary personal data:

• We need it to take steps at your request in order to enter into a contract with you. For example, an employment contract.
• We need it to comply with a legal obligation, e.g. the obligation not to employ someone who does not have the legal right to work in the UK.
• It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, it is in our legitimate interests to review and consider your personal data so that we can select the most appropriate candidate for the job.

What type of special category personal data do we hold about you, why, and on what legal grounds?

We will only collect, hold and use limited types of special category data about you during the recruitment process, as described below.

At the initial stages of recruitment, we collect, hold and use the following special category data about you:

Adjustments for disability/medical conditions
Information relevant to any request by you for adjustments to the recruitment process as a result of an underlying medical condition or disability. We use this information to enable us to carry out a fair, non-discriminatory recruitment process by considering/making reasonable adjustments to our process as appropriate. Our additional legal ground for using this information is that we need it to comply with a legal obligation/exercise a legal right in relation to employment – namely, the obligations not to discriminate, and to make reasonable adjustments to accommodate a disability – and such use is in line with our Data Protection Policy.

Health and diet questionnaire for positions which require food or drink consumption
For these positions, we collect information about your health and diet in a pre-employment questionnaire. We use this information to assess your capability to perform the job requirements, and whether you are fit to do the job with adjustments, to consider/arrange suitable adjustments and to comply with health and safety requirements.

How do we collect your personal data?

You provide us with most of the personal data about you that we hold and use, for example in your written application, by completing any assessments and during any interviews.

Some of the personal data about you that we hold and use may come from external sources. For example, a recruitment agency provides us with a shortlist of candidates. If we offer you a role, we will carry out pre-employment checks such as taking up references from past employers or education providers. In some circumstances, we may ask the Home Office for information about your immigration status to verify your right to work in the UK.

Who do we share your personal data with?

Recruitment agencies
We may engage recruitment agencies to provide us with the details of suitable candidates for our available vacancies, to communicate with those candidates and to handle administration in connection with the recruitment process. If we have received your initial application details from a recruitment agency, we will share with them any of your personal data that is necessary to enable them to fulfil their functions for us.

Medical/occupational health professionals
We may share information relevant to any request by you for adjustments to the recruitment process as a result of an underlying medical condition or disability with medical/occupational health professionals to enable us to identify what, if any, adjustments are needed in the recruitment process and, if you are successful, once you start work. This information may also be used by the medical/occupational health professionals to carry out assessments required by health and safety legislation.

Legal/professional advisers
We may share any of your personal data that is relevant, where appropriate, with our legal and other professional advisers, in order to obtain legal or other professional advice about matters related to you or in the course of dealing with legal disputes with you or other Job Applicants.

Home Office
We may share your right to work documentation with the Home Office, where necessary, to enable us to verify your right to work in the UK.

Consequences of not providing personal data

We only ask you to provide personal data that we need to enable us to make a decision about whether or not to offer you a role.

If you do not provide particular information to us, then we will have to make a decision on whether or not to offer you a role without that information, which in some cases could result in us deciding not to recruit you.

If you do not provide us with names of referees or a reference when asked, we will not usually be able to offer you the role. In addition, some of the personal data you provide to us is required by law. For example, if you do not provide us with the documentation we need to check your right to work in the UK, then we cannot by law employ you.

If you choose not to provide us with personal data requested, we will tell you about the implications of any such decision at the relevant time.

How long will we keep your personal data?

We will keep your personal data throughout the recruitment process in accordance with our Data Retention Policy. We will not keep your personal data for longer than we need it for our legitimate purpose.

If your application is successful, you will be issued with an Employee Privacy Notice when you start work.

If your application is unsuccessful, we will keep your personal data for up to 12 months from the date we notify you of our decision. There may be circumstances in which it is appropriate for us to keep particular items of your personal data for longer in which case we will take into account the following criteria:

• The amount, nature, and sensitivity of the personal data
• The risk of harm from unauthorised use or disclosure
• The purposes for which we process your personal data and how long we need the particular data to achieve these purposes
• How long the personal data is likely to remain accurate and up to date
• For how long the personal data might be relevant to possible future legal claims
• Any applicable legal, accounting, reporting or regulatory requirements that specify how long certain records must be kept

References

If you give us details of referees, we require you to inform them what personal data of theirs you are giving to us.

You must also give them our contact details and let them know that they should contact us if they have any queries about how we will use their personal data.

Contact Us

Campden BRI is the data controller of the personal information we collect from you. If you have any comments or complaints about the personal data we hold about you please contact:

The Data Protection Officer
Campden BRI
Station Road,
Chipping Campden
Gloucestershire, UK
GL55 6LD
Tel: +44(0)1386 842000
Email: dpo@campdenbri.co.uk

If we are unable to fully resolve any issue to your satisfaction you have the right to contact the Information Commissioner’s Office, whose contact details can be found at https://ico.org.uk/global/contact-us/.