DATA PROTECTION PRIVACY NOTICE (RECRUITMENT)

As part of any recruitment process, the Club collects and processes personal data relating to job applicants. The Club is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

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. 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.

  1. Who collects the information
    The Victory (Services) Association Limited trading as the Victory Services Club is a ‘data controller’ and gathers and uses certain information about you. We will comply with the data protection principles when gathering and using personal information, as set out in our Data Protection (Employment) Policy

2. About the information, we collect and hold
   We may collect a range of information about you during the recruitment process.
    This includes:

  • your name, address and contact details, including email address and telephone number;
  • details of your academic qualifications, skills, experience and employment history;
  • details of your referees;
  • information about your current level of remuneration, including benefit entitlements;
  • whether or not you have a disability for which the Club needs to make reasonable adjustments during the recruitment process; and information about your entitlement to work in the UK
  1.  How we collect the information
    The Club may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes provided by you, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

    The Club may also collect personal data about you from third parties, such as references supplied by former employers (details of whom you will have provided) which may include details of any conduct, grievance or performance issues, and attendance records. The Club will only seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

     You are under no contractual obligation to provide data to the Club during the recruitment process. However, if you do not provide the information, the Club may not be able to process your application properly or at all. You are required (by law) to provide certain categories of information, for example to enable us to verify your right to work in the UK

  2. Why we collect the information and how we use it

    We will typically collect and use this information for the following purposes:

    • to carry out a fair and informed recruitment process;
    • to take steps to enter into a contract;
    • for compliance with a legal obligation (e.g. our obligation to check that you are eligible to work in the United Kingdom); and
    • for the purposes of our legitimate interests, but only if these are not overridden by your interests, rights or freedoms.

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

    The Club will not use your data for any purpose other than the recruitment exercise for which you have applied.

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

  3. Automated decision-making
    Recruitment processes are not based solely on automated decision-making.
  4. How we may share the information

    Your information may be shared internally for the purposes of the recruitment exercise. This includes HR, interviewers involved in the recruitment process, and managers in the business area with a vacancy.

     In general, the Club will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The Club will then share your data with former employers to obtain references for you. However, in certain circumstances (e.g. in defence of legal claims), we may also need to share some of the above categories of personal information with other parties, such as HR consultants and professional advisers. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information as required to comply with the law.

     The Club will not transfer your data outside the European Economic Area.

  5. Where information may be held

    Information may be held at our offices, and with third party agencies, service providers, representatives and agents as described. Data will be stored in a range of different places, including the Club’s IT servers and other IT systems, including the Club’s email system.

  6. 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 is successful and you 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 [usually a period of six months], 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. If there is a clear business 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 your application is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. For further information, see our Data Protection Privacy Notice (Employment).

  7. Your rights

    As a data subject, you have a number of rights. You can:

    • access and obtain a copy of your data on request;
    • require the Club to change incorrect or incomplete data;
    • require the Club to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
    • object to the processing of your data where the Club is relying on its legitimate interests as the legal ground for processing.

    Please contact our Data Protection Officer (DPO) via dpo@vsc.co.uk if (in accordance with applicable law) you would like to exercise any of these rights. 

  8. Keeping your personal information secure

    The Club takes the security of your data seriously. The Club has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the proper performance of their duties. We limit access to your personal information to those who have a genuine business need to know it.

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

  9. How to complain

    We hope that our DPO can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner for further information about your rights and how to make a formal complaint.

May 2018

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