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GDPR Privacy Notice for all job applicants

Data Controller: Clearwell Mobility Ltd of Unit 3, 21 Albert Drive, Burgess Hill, West Sussex, RH15 9TN.

As part of any recruitment process, we will collect and process personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.

What information will we collect?

We will collect a range of information about you. This includes:

  • • Your name, address and contact details, including email address and telephone number;
  • • Details of your past job experience and employment history, qualifications and skills;
  • • Information about your current level of remuneration, including any benefit entitlements;
  • • Whether or not you have a disability for which the business needs to make any reasonable adjustments throughout the recruitment process;
  • • Information about your entitlement to work in the UK.

We may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

We may 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 record checks. We will seek information from third parties only once a job offer has been made to you and we will inform you that we are doing so.

Data will be stored in a range of different places, including on your application record, on the Human Resource Information Systems (HRIS) and on any other IT systems (including email).

Why do we process personal data?

We need to process data to take steps at your request prior to entering into a contract with you. We also need to process your data to enter into a contract with you.

In some cases, we will need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the UK before their employment starts.

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

We may process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.

For some roles, we are obliged to seek information about criminal convictions and offences (DBS checks). Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, we may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before we keep your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes the company directors and 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.

We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We 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.

We will not transfer your data outside the European Economic Area (EEA).

How do we protect your data?

We take the security of your data seriously. We have 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 our employees in the proper performance of their duties.

For how long do we keep your data?

If your application for employment is unsuccessful, we will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow us to keep your personal data on file, we will hold your data on file for a further 6 months for consideration for future employment opportunities. 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. At your induction you will receive a ‘General Data Protection Regulation and Privacy Policy for Employees’, the periods for which your data will be held are set out in our Data Retention Policy, which is available on request from the HR Department.

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 us to change incorrect or incomplete data;
  • • require us 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 we are relying on our legitimate interests as the legal ground for processing;
  • • Ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact Susan Wall (HR Department): swall@clearwellmobility.co.uk

If you believe that we have not complied with your data protection rights, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO). Full contact details including a helpline number can be found on the Information Commissioner’s Office web site (www.ico.org.uk). This website has further information on your rights and our obligations.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

Automated decision-making

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Related policies:

Data Retention Policy



Click here for a printable version of this policy.