Privacy Notice: supplementary information for job applicants

As part of our recruitment process, Carpmaels & Ransford LLP and Carpmaels and Ransford Services Limited (‘we’), as data controllers, collect and process personal data relating to job applicants. We are responsible for deciding how we hold and use personal data about you. This policy sets out 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).

1. The data we collect 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).

We collect, store and use a range of information about you in connection with your application for work with us. This includes:

• your title, name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration, including benefit entitlements (where specifically requested as part of the application process);
• whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• any other personal data held within your CV and/or cover letter or provided to us during an interview.

To ensure meaningful equal opportunity monitoring and reporting, we may invite you to share other personal data such as information about your race or national or ethnic origin; religious, philosophical or moral beliefs; or your sexual orientation; or your gender; or marital status; or age. Such information will be held separately from your application and will be collected and held on an anonymous basis.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose (this includes equality and/or diversity data). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

2. What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us 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.

3. How your personal data is collected and stored
We may collect your personal data in a variety of ways and from a variety of sources.

We collect personal data about candidates from the following sources:

3.1. You, the candidate, including data in application forms, CVs or resumes (collected via our applicant tracking system where relevant); obtained from your passport or other identity documents; or collected through interviews or other forms of assessment.

3.2. The recruitment agency through which you applied, namely your CV and cover letter.

3.3. Your academic institutions and named referees, from whom we obtain a standard reference.
We will seek this information from third parties only once we have made you a job offer and we will inform you that we are doing so.
We will store your personal data in a range of different places, including on your application record, in our applicant tracking system, in HR management systems and on other IT systems (including email).

4. How we use your personal data and the legal basis for doing so
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and/or
• where we need to comply with a legal or regulatory obligation.

Please refer to the ICO website (www.ico.org.uk) or refer to the glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

5. Purposes for which we will use your personal data
We need to process data to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you.

In some cases, we may need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the UK before employment starts.

We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

We may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics and to ensure meaningful equal opportunity monitoring and reporting; this will be collected and held on an anonymous basis.

We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. We would process such information to carry out our obligations and to exercise specific rights in relation to employment law.

6. Automated decision-making
Minor aspects of our recruitment processes incorporate automated decision-making.

7. Marketing
We do not add the data of job applicants to our marketing lists.

8. Who can access your data
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers 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.
It may be necessary from time to time for us to disclose your personal data to third parties or agents, including without limitation to the following:

(a) referees, academic institutions and external employment check providers to assist in the administration, processing and management of certain activities pertaining to prospective employees including external reference agencies (such as employee vetting and screening agencies); and

(b) regulatory bodies to whom we are obliged or required to disclose information including, Courts and Court-appointed persons, and relevant government departments and agencies.

We will not share your data with third parties other than our applicant tracking solution provider where relevant, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers and academic institutions to obtain references for you and with third party providers. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data 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.

9. International transfers
We do not currently transfer your personal data outside the European Economic Area (EEA). Were we to do so, transfer would always be made subject to appropriate technical and legal measures.

10. How long we retain and use personal data of job applicants

a) Successful applicants
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The purposes and periods for which your data will be held and processed will be provided to you in a new privacy notice which relates to employees.

b) Unsuccessful applicants
If your application for employment is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process so that we can consider you for any other opportunities that may arise. In addition, your personal data is retained 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 data in accordance with our data retention policy.

It is likely that we may wish to retain your personal data on file for further periods on the basis that a further opportunity may arise in future and we may wish to consider you for that. If so, we will write to you separately, seeking your explicit consent to retain your personal data for a further fixed period on that basis.

You can ask us to delete your data at any time. Please contact the HR team at careers@carpmaels.com if you have any queries.

11. Candidate Responsibilities
You should use all reasonable endeavours to keep us informed of any changes to your personal data. If you become aware of a data breach or a potential data breach in respect of personal data please report the matter immediately to the Data Protection Team (data.protection@carpmaels.com)