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Staff Survey Comments
 

Recruitment Privacy Notice
 

Data protection privacy notice (recruitment)

This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the application process. It applies to all individuals enquiring about or applying for a position at the School, including positions as a member of staff (full time or part time), contractors, workers, governors, volunteers and peripatetic staff. It also applies to individuals we will contact in order to find out more about our job applicants, including referees, or those that are provided by job applicants as an emergency contact.

This privacy notice is available to you because you are enquiring about a position at the School, or applying to work with us (whether as an employee, worker, or contractor). We are required to notify you of this information under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

WHO COLLECTS THE INFORMATION

Slindon College (‘School’) is a ‘controller’ in relation to personal data and gathers and uses certain information about you. This means that we are responsible for deciding how we hold and use your personal information.

The School’s contact details are in the webpage footer.

WHO WE COLLECT THE INFORMATION FROM

We obtain information about individuals from a number of different sources, including:

• You, as the individual enquiring about or applying for a position at the School;
• Your referee(s) (as named in your application);
• Your emergency contact(s);
• The Disclosure and Barring Service (DBS);
• The Teaching Regulation Agency (TRA);
• Any recruitment agency engaged by the School; and
• Publicly accessible sources (for example, information published on professional networking sites or in the public domain).

DATA PROTECTION PRINCIPLES

We will comply with the data protection law and principles when gathering and using personal information, as set out in our Data Protection Policy. This 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 a 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 safely and securely.

ABOUT THE INFORMATION WE COLLECT AND HOLD

The table in Part 1 of the Schedule below summarises the information we collect and hold, up to and including the shortlisting stage of the recruitment process, how and why we do so, how we use it and with whom it may be shared.

The table in Part 2 of the Schedule below summarises the additional information we collect before making a final decision to recruit, i.e. before making an offer of employment unconditional, how and why we do so, how we use it and with whom it may be shared.

The School will only process your information where it has a lawful basis to do so, and the most common bases on which we rely are:

• Where processing is necessary to take steps towards entering into an employment contract with you;
• Where processing is necessary to comply with a legal obligation (for example, to carry out statutory safeguarding and pre-employment checks as required by Keeping Children Safe in Education (KCSIE)); and
• Where processing is in the School’s legitimate interests (or those of a third party) and those interests are not overridden by your rights.

In limited circumstances, we may also process your information where it is required to protect your own vital interests or those of another individual, where it is in the public interest, or where you have given your specific consent.

We seek to ensure that our information collection and processing is always proportionate and necessary for specific legitimate purposes. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

IF YOU FAIL TO PROVIDE INFORMATION

You are not obliged to provide information to the School. However, if you do not provide certain information when requested, we may not be able to progress your application properly, or at all. For example, if you do not provide evidence needed for us to carry out mandatory safeguarding checks (such as those required under KCSIE), we will be unable to proceed with your application.

SENSITIVE INFORMATION AND INFORMATION RELATING TO CRIMINAL CONVICTIONS AND OFFENCES

The School maintains separate policies which set out in further detail how we handle sensitive information and criminal record information. These documents are available from the HR Officer. We encourage you to read these policies alongside this privacy notice.

AUTOMATED DECISION-MAKING

The School does not currently make any recruitment decisions based solely on automated processing. Should this position change, we will inform you in writing before any such processing takes place.

WHERE INFORMATION MAY BE HELD

Information may be held on the School’s premises in our filing systems and on our servers. It may also be held on our behalf by third party agencies, service providers and representatives.

HOW LONG WE KEEP YOUR INFORMATION

We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application, or the application you are supporting (e.g. as a referee) is successful and you (the job applicant) become employed by us, the nature of the information concerned and the purposes for which it is processed.

We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. This is likely to be for twelve months from the communication of the outcome of the recruitment exercise which takes account of both the time limit to bring claims and for claims to be received by the School. If there is a lawful reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised, and the longer period for which they will be kept.

If you are an applicant and your application is successful and you join the School, and once the twelve month period set out above comes to an end, we will keep only the recruitment information that is necessary in relation to your employment. For further information, see the Staff Privacy Notice.

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.

DATA SHARING

We may need to share your personal information with third parties as part of the recruitment process. These may include:

• The DBS;
• The TRA;
• The relevant local authority;
• Professional regulatory bodies outside the UK (if you have lived or worked abroad);and
• Any third-party service providers.

All third parties who process personal information on behalf of the School are required to take appropriate security measures to protect that information. We do not permit third-party service providers to use your personal information for their own purposes and only allow them to handle it in accordance with our instructions.

INTERNATIONAL TRANSFERS

The School does not transfer your personal information outside the United Kingdom.

YOUR DATA RIGHTS

Data protection legislation provides you with various rights in relation to your information. You have the right to:

• Access a copy of the information we hold about you (often referred to as a “subject access request”);
• Ask us to correct any information that is inaccurate or incomplete;
• Ask us to delete your information where there is no compelling reason for its continued processing;
• Object to the processing of your information where we are relying on a legitimate interest and there is something about your particular situation which makes you wish to object on this ground;
• Ask us to restrict (i.e. suspend) the processing of your information; and
• Ask us to transfer your information to another party in certain circumstances.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. The School will endeavour to respond to any such requests as soon as is reasonably practicable and in any event within statutory time-limits (which is generally one month, but actually fulfilling more complex or multiple requests, e.g. those involving third party information, may take 1-2 months longer).

To exercise any of these rights, please contact our [insert role title of individual with responsibility for data protection], Robert Draper, who can be contacted at draperr@slindoncollege.co.uk

You can find out more about your rights under applicable data protection legislation from the Information Commissioner’s Office website available at www.ico.org.uk.

KEEPING YOUR PERSONAL INFORMATION SECURE

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes personal information being locked away, password protected or encrypted. We limit access to your personal information to those who have a genuine need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected personal data breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

HOW TO COMPLAIN

Under data protection legislation, you have the right to make a complaint directly to us as your data controller. If you have any queries about this Privacy Notice or how we process your personal data, or if you wish to exercise any of your rights under applicable law or to make a complaint, you may contact Robert Draper. We will acknowledge any complaint within 30 days of receipt and will investigate and inform you of the outcome of your complaint without undue delay (keeping you informed of progress as necessary).

If you are not satisfied with the outcome of your complaint, or if you feel the School has not handled it appropriately, you have the right to complain to the Information Commissioner’s Office (ICO).