Privacy Notice for Job Applicants
Low Carbon Contracts Company (“we”, “us”, “LCCC”) are committed to protecting the privacy and security of your personal information and to being transparent about how it collects and uses that data. Please read this Privacy Notice as it sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us in connection with our recruitment processes and in accordance with data protection law.
For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Low Carbon Contracts Company. This means that we are responsible for deciding how we hold and use personal information about you.
We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software), to assist with our recruitment process. We use Pinpoint to process personal information as a data processor on our behalf. Pinpoint is only entitled to process your personal data in accordance with our instructions.
Where you apply for an opportunity posted by us, these Privacy Notice provisions will apply to our processing of your personal information, in addition to our other Privacy Notice which is available on our website
Data Protection Principles
We will comply with data protection law, which requires that 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; and
6) kept securely.
Your Personal Information
Information we collect from you
We collect and process some or all of the following types of information about you:
· Information that you provide when you apply for a role. This includes information provided through an online application, via email, in person at interviews and/or by any other method. In particular, we process personal details such as name, email address, address, date of birth, qualifications, experience and any information relating to your employment history, skills and experience that you provide to us.
· Information about your entitlement to work in the UK in order to check a successful applicant's eligibility to work in the UK before employment starts.
· Information about your current level of renumeration, including benefit entitlements.
· We may collect health information regarding whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process.
· If you contact us, we may keep a record of that correspondence.
· Details of your visits to our careers website including, but not limited to, traffic data, location data and other communication data, the site that referred you to our careers website and the resources that you access.
LCCC collects this information in a variety of ways. For example, data might be contained in CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
LCCC will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. LCCC will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
We may be obliged to seek information about criminal convictions and offences. Where LCCC seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment/comply with a regulatory requirement to establish whether or not an individual has committed an unlawful act or been involved in dishonesty or other improper conduct.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Who has access to your information
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR 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.
Any information you provide to us via your CV, or the data you input into Pinpoint, will be visible to certain members of our People and Organisational Development team, and the hiring managers specified for the relevant role.
We collect and process personal data to carry out our obligations and exercise specific rights in relation to employment. LCCC will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. LCCC will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
Information we collect from other sources
PinPoint provides us with the facility to link the data that you provide to us with other publicly available information about you that you have published on the Internet and have chosen to link to your application. The option to link these public sources, such as LinkedIn or other social media profiles, to your application, is not mandatory.
Lawful basis for processing
LCCC has a legitimate interest in keeping records of the recruitment process and conducting data analytics studies with some of the data processed in order to review and better understand recruitment, employee retention and attrition rates. LCCC may also need to process data from job applicants to respond to and defend against legal claims.
Purposes of processing
We use information held about you in the following ways:
· To consider your application in respect of a role for which you have applied.
· To consider your application in respect of other roles.
· To communicate with you in respect of the recruitment process.
· To enhance any information that we receive from you with information obtained from third party data providers.
· To find appropriate candidates to fill our job openings.
· To help Pinpoint improve their services.
Automated decision making / profiling
We may leverage Pinpoint’s technology to help us select appropriate candidates for us to consider based on criteria we have identified. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our team.
How we store your personal data
LCCC takes the security of your data seriously. We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being lost, used or accessed in any unauthorised way, accidentally destroyed, altered or disclosed. We limit access to your personal data to those who have a genuine business need to view it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have appropriate procedures in place to deal with any suspected data breach and will notify you and any applicable regulator of a suspected personal data breach where we are legally required to do so.
Where we store your personal data
The data that we collect from you and process using Pinpoint’s Services will be transferred to and stored at one of several datacentre locations in Amsterdam (Netherlands) and may be synchronised to one of several datacentre locations in London (United Kingdom) for backup and redundancy purposes.
How long we keep your personal data
We retain all candidate data for a period of 12 months from the last activity actioned on your profile, after this period, the data is deleted.
Your personal data may also be deleted earlier in one of the following occurrences:
· Deletion of your personal information by you via the Manage Your Data
· Receipt of a written request from you to us to delete your personal information.
By submitting your personal data, you agree to our processing of this data.
Under the General Data Protection Regulation you have a number of important rights. In summary, those include rights to:
· access to your personal data and to certain other supplementary information, that this Privacy Notice is already designed to address
· require us to correct any mistakes in your information which we hold
· request the erasure of personal data concerning you, in certain situations
· request access to personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transmit those data to a third party, in certain situations
· object at any time to the processing of personal data concerning you for direct marketing
· object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
· object in certain other situations to our continued processing of your personal data
· otherwise restrict our processing of your personal data in certain circumstances
If you would like to exercise any of those rights, please either:
· contact us using our contact details below, ensuring we have enough information to identify you, proving your identity and address and confirming which information to which your request relates
How to complain
We hope that we can resolve any query or concern you raise about our use of your information. If you have any questions about how we handle your personal information, you can contact our DPO at: DPO@lowcarboncontracts.uk