Privacy Notice: Recruitment

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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.

Who collects the information

Castlegate & Derwent Surgery is a ‘data controller’ and gathers and uses certain information about you.

Data protection principles

We will comply with the data protection principles when gathering and using personal information, as set out in our Data Protection & GDPR Policy.

About the information we collect and hold

We may collect the following information up to and including the shortlisting stage of the recruitment process:

Your name and contact details (i.e. address, home and mobile phone numbers, email address);
Details of your qualifications, experience, employment history (including job titles and working hours) and interests;

We may collect the following information after the shortlisting stage, and before making a final decision to recruit. However you must (by law or to enter into your contract of employment) give this information to us, if we request it, to enable us to verify your right to work and suitability for the position:

Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers;
Information about your academic and professional qualifications;
Information about your criminal record, in criminal records certificates (CRCs) and enhanced criminal records certificates (ECRCs);
Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
A copy of your driving licence.

How we collect the information

We may collect this information from you, your referees (details of whom you will have provided), your education provider (, the relevant professional body) (, the Disclosure and Barring Service (DBS)) and the Home Office.

Why we collect the information and how we use it

We will typically collect and use this information for the following purposes (other purposes that may also apply are explained in our Data Protection & GDPR Policy).

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);
for the performance of a task carried out in the public interest; and
for the purposes of our legitimate interests, but only if these are not overridden by your interests, rights or freedoms.

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.

How we may share the information

We may also need to share some of the above categories of personal information with other parties, such as HR consultants and professional advisers. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also need to share some personal information with our regulators or as needed to follow the law.

Sensitive personal information and criminal records information

Further details on how we handle sensitive personal information and information relating to criminal convictions and offences are set out in our Data Protection & GDPR Policy as needed under the Data Protection Act 2018), the employee can access the policy/policies on TeamNet Library.

The information set out in Part A: Up to and including the shortlisting stage 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 information set out in Part B: Before making a final decision to recruit 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. 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.

Where information may be held

Information will be held at our offices on-site.

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, considering 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 3 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, we will keep only the recruitment information that is necessary in relation to your employment.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business 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 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.

How to complain

We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner via their website or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

The Schedule

Part A: Up to and including the shortlisting stage

Your name and contact details (i.e. address, home and mobile phone numbers, email address)

How we collect the info: From you
Why we collect the info: Legitimate interest: to carry out a fair recruitment process Legitimate interest: to progress your application, arrange interviews and inform you of the outcome at all stages
How we use and may share the info: To enable HR personnel ( or the manager of the relevant department) to contact you to progress your application, arrange interviews and inform you of the outcome To inform the relevant manager or department of your application

Details of your qualifications, experience, employment history (including job titles and working hours) and interests

How we collect the info: From you, in the completed application form and interview notes (if relevant)
Why we collect the info: Legitimate interest: to carry out a fair recruitment process Legitimate interest: to make an informed decision to shortlist for interview and (if relevant) to recruit
How we use and may share the info: To make an informed recruitment decision The person making the shortlisting decision will receive pseudonymised or anonymised details only; if you are invited for interview, the interviewer will receive non-anonymised details

Your name contact details and details of your qualifications, experience, employment history and interests

How we collect the info: From you, in the completed application form and interview notes (if relevant)
Why we collect the info: Legitimate interest: to carry out a fair recruitment process
How we use and may share the info:

Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs

How we collect the info: From you, in a completed anonymised equal opportunity monitoring form
Why we collect the info: To comply with our legal obligations and for reasons of substantial public interest ( (equality of opportunity or treatment))
How we use and may share the info: To comply with our equal opportunities monitoring obligations and to follow our equality and other policie

Information regarding your criminal record

How we collect the info: From you, in your completed application form and interview stages
Why we collect the info: To comply with our legal obligations For reasons of substantial public interest preventing or detecting unlawful acts, ( suspicion of terrorist financing or money laundering in the regulated sector) and protecting the public against dishonesty
How we use and may share the info: To make an informed recruitment decision To carry out statutory checks Information shared with DBS and other regulatory authorities as required

Details of your referees

How we collect the info: From your completed application form
Why we collect the info: Legitimate interest: to carry out a fair recruitment process In the regulated sector, to comply with our legal obligations to obtain regulatory references
How we use and may share the info: To carry out a fair recruitment process To comply with legal/regulatory obligations Information shared with relevant managers, HR personnel and the referee

Part B: Before making a final decision to recruit

Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers

How we collect the info: From your referees (details of whom you will have provided)
Why we collect the info:Legitimate interest: to make an informed decision to recruit To comply with our legal obligations Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice
How we use and may share the info: To obtain the relevant reference about you To comply with legal/regulatory obligations Information shared with relevant managers and HR personnel

Information regarding your academic (and professional) qualifications

How we collect the info: From you, from your education provider , from the relevant professional body
Why we collect the info: Legitimate interest: to verify the qualifications information provided by you
How we use and may share the info: To make an informed recruitment decision

Information regarding your criminal record, in criminal records certificates (CRCs) and enhanced criminal records certificates (ECRCs)

How we collect the info: From you and from the Disclosure and Barring Service (DBS)
Why we collect the info: To perform the employment contract To comply with our legal obligations Legitimate interest: to verify the criminal records information provided by you For reasons of substantial public interest preventing or detecting unlawful acts, ( suspicion of terrorist financing or money laundering in the regulated sector) and protecting the public against dishonesty
How we use and may share the info: To make an informed recruitment decision To carry out statutory checks Information shared with DBS and other regulatory authorities as required

Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information

How we collect the info: From you and, where necessary, the Home Office
Why we collect the info: To enter into/perform the employment contract To comply with our legal obligations Legitimate interest: to maintain employment records
How we use and may share the info: To carry out right to work checks Information may be shared with the Home Office

A copy of your driving licence

How we collect the info: From you
Why we collect the info: To enter into/perform the employment contract
How we use and may share the info: for photographic ID

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