GDPR PRIVACY NOTICE FOR APPLICANTS WHAT IS THE PURPOSE OF THIS DOCUMENT?
St George’s Academy Trust 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 and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). It applies to all applicants. St George’s Academy Trust 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. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR). It is important that you read and retain 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 and what your rights are under the data protection legislation.
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 certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.
We will collect information that is specifically provided by you as part of an application process.
We will collect the following (but not limited to):
The information you have provided on your application form and any covering letter, including your name, address, personal email address, date of birth, telephone number, employment history, qualifications.
- CV (if applicable)
- Any information you provide to us during interview, including any answers to application questions.
- Any other information you provide to us in support of your application 2 We may also collect, store and use the following types of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences. By agreeing to this privacy statement, you are allowing us to form a contract that will mean we can use your details and information presented so that we can assess your suitability for employment with us and carry out our statistical analysis.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
You, the candidate.
Recruitment agencies, from which we collect the following categories of data:
- Name, address, personal email address, date of birth, telephone number, employment history, qualifications, information about criminal convictions and offences.
- Our recruitment process requires that we contact the referees provided by you as part of our checks to ascertain suitability of employment. The content of the reference will not be shared without the referee’s permission. We also ask if we can contact your referees before the interview stage
We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role/work to which you have applied.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Monitor equal opportunities information.
- Comply with legal or regulatory requirements. It is in our legitimate interests to decide whether to appoint you to the role/work to which you have applied. We also need to process your personal information to decide whether to enter into a contract with you. If you fail to provide personal information 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.
How we use particularly sensitive personal information We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
- 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. 3 Information about criminal convictions We envisage that we will process information about criminal convictions. We will collect information about your criminal convictions history if we would like to offer you work with the Academy. We are required to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. All roles within the Academy are exempt from the Rehabilitation of Offences Act 1974. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. CCTV We have installed CCTV for the purpose of student, staff and public safety and crime prevention and detection. We will only disclose CCTV images to others who intend to use the images for the purposes stated above only in exceptional circumstances e.g. in the case of a missing child. CCTV will be processed in accordance with the GDPR principles. Automated decision-making You will not be subject to decisions that will have a significant impact on you based solely on automated decisionmaking. DATA SHARING 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. We may transfer your personal information outside the EU. 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 it is necessary to for the purposes of processing your application or where we have another legitimate interest in doing so.
We have put in place measures to protect the security of your information. Details of these measures are available upon request. 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. 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 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 6 months after we have communicated to you our decision not to appoint you to the role/work to which you have applied. 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. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations. If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis. Where we have confirmed our decision to appoint you to the role/work to which you have applied, we will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the HR Office. For further information, please refer to the GDPR Privacy Notice for Employees, Workers and Contractors.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
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 email@example.com. Right to withdraw consent You have the right to withdraw your consent to us processing your personal data for the purposes of the recruitment exercise at any time. In such a case, we will not process more personal data than is required under the circumstances. To withdraw your consent, please contact firstname.lastname@example.org. Once we have 5 received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely. Where you exercise your right to object or withdraw your consent to us processing your personal data, we may process your personal data without your knowledge or consent where we are permitted or required by law or regulatory requirements to do so. Data protection officer
We have appointed a data privacy officer (DPO) to oversee compliance with this privacy notice. Our Data Protection Officer role is provided by: GDPR Sentry. If you have any questions about this privacy notice or how we handle your personal information, please contact email@example.com.