Data controller: Limbless Association
Data protection officer: Deborah Bent, CEO
As part of any recruitment process, we collect and process personal data relating to job applicants. We are committed to being transparent about how we collect and use this data and to meeting our data protection obligations.
What information does the Limbless Association collect?
The Limbless Association collects 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;
The Limbless Association collects 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.
The Limbless Association will also collect personal data about you from third parties, such as references supplied by former employers. We will seek information from third parties only once a job offer to you has been made and will inform you that we are 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 Limbless Association 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 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 employment starts.
The Limbless Association 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. We may also need to process data from job applicants to respond to and defend against legal claims.
Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of job applicants, employees or workers and has concluded that they are not.
We 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. Where we seek this information, we do so to comply with a regulatory requirement to establish whether or not an individual has committed an unlawful act or been involved in dishonesty or other improper conduct/reasons of substantial public interest.
The organisation will not use your data for any purpose other than the recruitment exercise for which you have applied.
Who has access to 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.
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 checks providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks if required.
The Limbless Association will not transfer your data outside the European Economic Area.
How does the organisation protect 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 does the organisation keep data?
If your application for employment is unsuccessful, the organisation will hold your data on file for 12 months after the end of the relevant recruitment process. At the end of that period or once you withdraw your consent, your data will be 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.
As a data subject, you have a number of rights. You can:
• access and obtain a copy of your data on request;
• require the Limbless Association 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;
• object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing; and
• 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 Debbie Bent, by email at firstname.lastname@example.org.
You can make a subject access request by completing the Limbless Association’s form for making a subject access request.
If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner.
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. If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the UK and satisfactory references.