Applicant Privacy Notice
Curtis Fitch Limited, Formal House, St George’s Place, Cheltenham, GL50 3PN is the Data Controller.
As part of any recruitment process, the organisation collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does Curtis Fitch collect?
The Company collects and processes a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.]
The organisation collects this information in a variety of ways. For example, data might be contained in, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
The organisation 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.
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).
Why does the Company process personal data?
The organisation needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.
The organisation 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 organisation to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.
The organisation processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where the organisation processes other special categories of data, such as information about ethnic origin, sexual orientation, health, religion or belief, age, gender or marital status, this is done for the purposes of equal opportunities monitoring with the explicit consent of job applicants, which can be withdrawn at any time.
The organisation will not use your data for any purpose other than the recruitment exercise for which you have applied.
Who has access to your data?
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment 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.
The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with former employers to obtain references for you.
Some of your personal information may be stored in GSuite and on HubSpot where your data maybe transferred outside theEuropean Economic Area, however both have the relevant safeguards in place namely the Privacy Shield.
How does the Company protect data?
The Company takes the security of data seriously and has gained ISO27001 certification. The Company has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed and is not accessed except by its employees in the performance of their duties.
Where the Company engages third parties to process personal data on its behalf they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organizational measures to ensure the security of data.
For how long does the Company keep data?
If your application for employment is unsuccessful, the organisation will hold your data on file for six months after the end of the relevant recruitment process. At the end of that period or once you withdraw your consent, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
What are 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 Company to change incorrect or incomplete data;
- Require the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- Object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing; and
- Ask the Company to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the Company’s legitimate grounds for processing data.
If you would like to exercise any of these rights you should make a subject access request and contact [email protected] If you believe the Company has not complied with your data protection rights you can complain to the Information Commissioner’s Office.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.