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1. When you are applying for a role with Coastal Marks Ltd (whether as an employee, worker or contractor), we need to know certain information about you. This Privacy Notice explains the type of information we will process about you during the recruitment and selection process, why we are processing it and how that processing may affect you.
2. References in the Privacy Notice to employment, work (and similar expressions) include any prospective arrangement we may have under which an individual provides us with work or services.
What personal information we may hold and why we process it
3. In connection with your application for work with us, we will collect, store and use the following categories of personal information about you:
Recruitment and Selection
Examples of personal information that may be processed
Standard data related to your identity (e.g. your name, address, email address, ID information and documents, telephone numbers, place of birth, nationality and contact details); professional experience and education (including university degrees, academic records, professional licenses, memberships and certifications, awards and achievements, and current and previous employment details); financial information (including current salary information); language skills; and any other personal information that you present us with as part of your application related to the fulfilment of the role.
Information concerning your application and our assessment of it, your references, any checks we may make to verify information provided and any information connected with your right to work.
If necessary, we will also process information concerning your health, any disability and in connection with any adjustments to working arrangements.
Grounds for processing
Contract, Legal obligation, Legitimate interests
How we use particularly sensitive personal information
4. We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
How is your personal information collected?
5. We collect personal information about you from the following sources:
- You, the candidate.
- Recruitment agencies, job boards, social networking sites, not for profit organisations (such as ELBA, BASE, Job Centre Plus) and learning and development organisations where you have provided them with your application details in the first place and who pass those details on to us.
- Your named referees.
How will we use information about you?
6. We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
7. Having received either your CV and covering letter or your application form, we will process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and/or carry out a criminal record and/or carry out any other checks before confirming your appointment.
8. It is in our legitimate interests to decide whether to appoint you to role since it would be beneficial to our business to appoint someone to the role. We also need to process your personal information to decide whether to enter into a contract with
If you fail to provide personal information
9. If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How do we keep your personal information secure?
10. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
11. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data when being sent. Once we receive your personal information though, we have security measures in place to protect it.
12. If you would like more information on these measures, please contact us on the details set out at “Contact Details” below.
How long do we keep your personal information?
13. We will retain your personal information for a period of 6 months after we have communicated to you our decision about whether to appoint you to work for us. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated againstcandidates on prohibited grounds and that we have conducted the recruitment and selection exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.
14. If we wish to retain your personal information on file after the standard 6 month retention period, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
15. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might we share your personal information with third parties?
16. We will only disclose your personal information outside Coastal Marks Ltd if disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you.
17. We will disclose your data if it is necessary for our legitimate interests as an organisation or the interests of a third party (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy). Where necessary, we will also disclose your personal information if you consent, where we are required to do so by law and in connection with criminal or regulatory investigations.
18. Specific circumstances in which your personal information may be disclosed to third parties include:
- to recruitment agencies to discuss your application;
- to law enforcement agency to respond to requests or where required by applicable laws, pursuant to court orders, or arbitral or tribunalorders or rules of procedure, or to government regulations departments or agencies or regulatory bodies (including disclosures to tax and employment authorities), employment and any other regulatory bodies);
- on a confidential basis to our advisers for example to our lawyers for the purposes of seeking legal advice or to further Coastal Marks Ltd interests in legal proceedings and to our accountants for auditing purposes;
- on an aggregated and anonymised basis to relevant regulators as part of a formal request for diversity data.
19. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.
Access to your personal information and other rights
20. We try to be as open as we reasonably can about personal information that we process. If you would like specific information, just ask us.
21. You also have a legal right to make a “subject access request”. These requests must be made in writing. If you exercise this right and we hold personal information about you, we are required to provide you with information on it, including giving you a description and copy of the personal information and telling you why we are processing it.
22. If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity. We will provide you with any information you are entitled to within one month of receipt of your request unless your request is particularly complex in which case we will let you know if we need more time.
23. As well as your subject access right, you may have a legal right to have your personal information rectified or erased, to object to its processing or to have its processing restricted. If you have provided us with data about yourself (for example your address or bank details), you have the right to be given the data in machine readable format for transmitting to another data controller. This only applies if the ground for processing is Consent or Contract.
Right to withdraw
24. When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment and selection exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact your main contact in our business if you sent your CV in directly or please email us on the email provided in ‘Contact Details’ below. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal information securely.
25. Please note that generally the controller of your personal information will be the business that is recruiting you within Coastal Marks Ltd. The details of all entities in Coastal Marks Ltd are listed in Annex 1.
26. Questions, comments and requests regarding your personal information are welcomed. If you have queries or complaints relating to our processing of your personal information, you should raise these with your main contact in our business in the first instance or by contacting our manager on firstname.lastname@example.org
27. You may also raise complaints with the Information Commissioner’s Office directly. Further information, including contact details, is available at https://ico.org.uk.
Status of this notice
28. This notice may be amended by us at any time. Nothing in this notice is intended to create an employment relationship between us and any non-employee providing services to us.
Annex 1. INFORMATION SPECIFIC TO DIFFERENT Coastal Marks Ltd CONTROLLERS
If you are being recruited in the UK by one of the following companies, the following additional information applies.
The statutory regulator is the ICO.
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