APPLICANT PRIVACY NOTICE
What is the purpose of this document?
Welsh Refugee Council is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as a volunteer, 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).
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
- 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.
The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
- The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, employment history, qualifications.
- Any information you provide to us during the application process including tests and interviews.
- Any information you provide to us in any correspondence including email, telephone or letter.
We may also collect, store and use the following “special categories” 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 or disability, health and sickness records.
- Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about applicants from:
- You, the applicant.
- Disclosure and Barring Service in respect of criminal convictions.
- Your named referees, from whom we collect dates of employment, job title and suitability for the role as requested on our Reference Request Form.
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.
- Carry out reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint you since it would be beneficial to our business to appoint someone to the vacancy. We also need to process your personal information to decide whether to enter into a volunteering agreement, consultancy agreement or contract of employment with you.
Having received your application form, we will process that information to decide whether you meet the basic requirements to be shortlisted. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to make an offer to you. If we decide to make an offer it will be dependent on us receiving references that are satisfactory to us, a satisfactory criminal record check and (for paid work) you establishing your eligibility to work in the UK.
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 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 an interview.
Any further sensitive data that you provide on your Curriculum Vitae, covering letter or application form will not be processed but will be stored safely in your personnel file. We may process this data if you are offered employment with the company in accordance with our Privacy Notice for Employees, Workers and Contractors.
Information about criminal convictions
We envisage that we will process information about criminal convictions for positions which are required to work with vulnerable clients as well as senior roles within the organisation. This includes volunteers and the Volunteer Co-ordinator and Partnerships Officer.
We will set out in an offer letter to you if we intend to collect information about your criminal convictions history. 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. In particular:
- We are legally required by OISC to carry out criminal record checks for those carrying out client facing work.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application: members of the interview panel (they may be from partner organisations or funders) and our HR provider. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information 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.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. Details of these measures may be obtained from our Executive Director of Resources.
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?
APPLICATIONS from EMPLOYEES, WORKERS, CONTRACTORS and VOLUNTEERS for ADVERTISED POSITIONS: If you have not been shortlisted for the vacancy, such that you have not heard from us by the date specified on the job advertisement, we will shred your personal information 6 months after this date. If you are shortlisted and invited to interview then we will retain your personal information until 6 months after the successful applicant has started in the role. This is in case the original appointment is not successful and we need to re-recruit, or your skills make you a suitable applicant for a different vacancy within WRC. If you are successful then your personal information will be transferred to your personnel file.
SPECULATIVE APPLICATIONS – PAID EMPLOYMENT: Applications made on a speculative basis i.e. not in response to an advertised position, will be destroyed immediately.
SPECULATIVE APPLICATIONS – VOLUNTEERS: Speculative applications to volunteer for us will be acknowledged by email and held on file for 6 months. If no volunteering opportunities arise within that time the application will be destroyed.
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 further fixed period.
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 the Executive Director of Resources in writing.
Please note that any references that we obtain about you are given in the strictest confidence, and are exempt from Subject Access Requests. Therefore you would be unable to request a copy of any reference we gather about you through the means of a Subject Access Request to WRC, your previous employer, or through escalating the issue to the Information Commissioner’s Office. Providing referee details and signing this document confirms that you are satisfied with the above explanation and give WRC permission to collect references on your behalf.
Right to withdraw consent
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the Executive Director of Resources. Once we have 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.
Data protection officer
We have appointed the Chief Executive Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the them. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.