APPLICATION PRIVACY NOTICE
1.1 Silverbond Enterprises Ltd trading as the Park Lane Club (“PLC”) takes the security and privacy of your data seriously and is aware of its obligations under the General Data Protection Regulation (GDPR). We need to gather and use information or ‘data’ about you to further your application in the recruitment process and to process your data to comply with our legal obligations (e.g., it is mandatory to check a successful applicant’s eligibility to work in the UK before employment starts). This Policy sets out the types of data we collect, hold and process and your rights in relation to your personal data.
1.2 This policy applies to all new job applicants, whether you apply by email, through our web site or speculatively in person. If you fall into one of these categories then you are a ‘data subject’ for the purposes of this policy.
1.3 PLC is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data.
2. Data Protection Principles
2.1 Personal data must be processed in accordance with six ‘Data Protection Principles’. It must:
• be processed fairly, lawfully and transparently;
• be collected and processed only for specified, explicit and legitimate purposes;
• be adequate, relevant and limited to what is necessary for the purposes for which it is processed;
• be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay;
• not be kept for longer than is necessary for the purposes for which it is processed; and
• be processed securely.
3. How we define personal data
3.1 ‘Personal data’ means information which relates to a living person who can be identified from that data (a ‘data subject’) on its own, or when taken together with other information which is likely to come into our possession. It does not include anonymised data.
3.2 This policy applies to all personal data whether it is stored electronically, on paper or on other materials.
3.3 This personal data might be provided to us by you, or someone else (such as a former employer or your doctor), or it could be created by us. It could be provided or created during the recruitment process.
3.4 We will collect and use the following types of personal data about you:
• your name, date of birth and contact details;
• CV, references, qualifications, industry knowledge, and membership of any professional bodies and details of any pre-employment assessments;
• your gender, marital status, nationality (as per passport), and national insurance number
• information about your eligibility to work in the UK
• your identification documents including passport and driving licence and information in relation to your immigration status and right to work for us;
3.5 We may also collect, store and process the following special categories of more sensitive personal information:
• The number of sick days you have had in the last 12 months and the reasons why;
• Any criminal convictions and offences;
• Participation of a Self-Exclusion scheme;
3.6 We may also collect some sensitive personal data about you, such as disability information. We will only do this to make reasonable adjustments to enable candidates to apply for jobs with us, attend interviews and to start work with us if successful. Also, to ensure we meet our legal obligations when recruiting.
4. How will we process your personal data?
4.1 Processing includes collecting, using and storing. PLC will process your personal data (including special categories of personal data) in accordance with our obligations under the GDPR.
4.2 We will use your personal data to:
• contact you to progress your application;
• assess your suitability for the role for which you have applied;
• Enter into a contract of employment with you and meets its obligations in relation to your contract of employment;
• Comply with any legal obligation, for example to check your right to work in the UK or as required by the Transfer of Undertakings Regulations. For certain positions, it is necessary to carry out a criminal records check to ensure that individuals are permitted to undertake a particular role;
• To protect your interests;
• Carry out credit checks, proof of identity checks, enhanced due diligence checks, and checks to see if you are enrolled onto any self-exclusion scheme.
We will not use your personal data for an unrelated purpose without telling you about it and the legal basis that we intend to rely on for processing it.
We will process your personal data for the purpose of our legitimate business interest, which is when we will keep your personal data on file for a period of one (1) year should you be an unsuccessful applicant, in case there are future employment opportunities for which you may suited.
5. Lawful bases for processing your personal data
5.1 Our lawful bases for processing your personal data is either the consent you give for the processing during the application process, or when the processing is necessary for the purpose of our legitimate business interests;
5.2 If you choose not to provide us with certain personal data, you should be aware that it may affect your application;
5.3 We do not need your consent to process special categories of your personal data when we are processing it for the following purposes, which we may do:
• where it is necessary for carrying out rights and obligations under employment law;
• where it is necessary to protect your vital interests or those of another person where you/they are physically or legally incapable of giving consent;
• where you have made the data public;
• where processing is necessary for the establishment, exercise or defence of legal claims; and
• where processing is necessary for the purposes of occupational medicine or for the assessment of your working capacity.
5.4 We do not take automated decisions about you using your personal data or use profiling in relation to you.
5.5 If your job application is unsuccessful, and unless you ask us not to, your details will be added to our talent pool and we may make contact with you again. This is because it is in our legitimate interests to maintain the details of, and stay in contact with, suitable candidates for future roles. You can object to being in our talent pool at any time, by contacting us at email@example.com or by writing to us at the address below.
6. Sharing your personal data
6.1 We do not send your personal data outside the European Economic Area. If this changes you will be notified of this and the protections which are in place to protect the security of your data will be explained.
6.2 Our HR team will have access to all of the information you provide during the application process, and may share it with Heads of Departments who will be carrying out screening and interviews.
7. How long we retain your data
7.1 We will retain your personal data for only as long as is necessary for the recruitment process. If your candidacy is successful and you are employed by us, your data will be processed and retained as set out in our employee privacy notice, provided to you with your employment paperwork.
7.2 If your candidacy is not successful, we will retain your CV, application details and interview notes for 12 months (from the date of first receipt of your details). During this time, we may add your information to our talent pool unless you ask us not to or subsequently object to us doing so.
7.3 We will also retain personal data where it is necessary to comply with our legal obligations or as necessary in relation.
8. Your rights
8.1 You have the right to access your own personal data by way of a subject access request.
• Data subjects, including employees, workers and contractors can make a ‘subject access request’ (‘SAR’) to find out the information we hold about them.
• If you would like to make a SAR in relation to your own personal data you should make this in writing to the Data Protection Officer. We must respond within one month unless the request is complex or numerous in which case the period in which we must respond can be extended by a further two months.
• There is no fee for making a SAR. However, if your request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse to respond to your request.
8.2 You can require us to correct any inaccuracies in your personal data.
8.3 You have the right to request that we erase your personal data where we were not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected.
8.4 While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made.
8.5 You have the right to object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.
8.6 You have the right to receive a copy of your personal data and to transfer your personal data to another data controller.
8.7 With some exceptions, you have the right not to be subjected to automated decision-making.
8.8 You have the right to be notified of a data security breach concerning your personal data.
8.9 In most situations we will not rely on your consent as a lawful ground to process your data. If we do however request your consent to the processing of your personal data for a specific purpose, you have the right not to consent or to withdraw your consent later.
8.10 If you wish to exercise any of the rights listed above you should contact the Data Protection Officer by email to firstname.lastname@example.org .
8.11 You have the right to complain to the Information Commissioner. You can do this be contacting the Information Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website (www.ico.org.uk). This website has further information on your rights and our obligations.
9. How to contact us
9.1 You can contact us in relation to data protection and this privacy notice by writing to:
Silverbond Enterprises Limited
32 Hertford Street,
9.2 Alternatively, you can email us at email@example.com