GenTec Privacy Notice
Genesis Technical Recruitment (hereafter referred to as GenTec or ‘we’ or ‘us’) have a strict privacy policy to ensure all personal data of applicants is treated correctly and in line with current regulations.
GenTec promise to treat your personal details appropriately and we guarantee that we will never sell or pass on your details without your prior knowledge and consent to do so.
Applicant Privacy Notice
This Applicant Privacy Notice sets out what personal data we collect and hold about you and how we use it during and after the recruitment process. It applies to anyone who is applying to work for us, whether as an employee, worker, contractor, consultant, intern, or director (together referred to as ‘Applicant’ or ‘you’).
Please note that we will not necessarily hold, use or share all the personal data described in this Privacy Notice in relation to you. The specific types of data that we will hold, use or share will depend on the role for which you have applied for, the nature of the recruitment process, how far you progress in the process as well as your personal circumstances.
We are required by data protection law to give you the information in this Privacy Notice.
It is important that you read the Privacy Notice carefully, together with any other similar or additional information that we might give you from time to time about how we collect and use your personal data. Should your application for permanent employment be successful, when you start work, you will be supplied with your new Employer’s Privacy Notice; or if you are employed by GenTec, we will provide you with another privacy notice that explains how we deal with your personal data whilst you are working for us as an employee.
The General Data Protection Regulations (GDPR) are effective from 25th May 2018. Please note that GDPR does not give you any contractual rights and we may update this Privacy Notice at any time.
Who is the controller?
Genesis Technical Recruitment Limited, 1 Church Court, Cox Street, Birmingham B1 3RD is the “controller” for the purposes of data protection law. This means that we are responsible for deciding how we hold and use personal data about you.
What is personal data?
Personal data means any information relating to a living individual who can be identified (directly or indirectly) in particular by reference to an identifier (e.g. name, NI number, employee number, email address, physical features). It can be factual (e.g. contact details or date of birth), an opinion about an individual’s actions or behaviour, or information that may otherwise impact that individual in a personal or business capacity.
Data protection law divides personal data into two categories: ordinary personal data and special category data. Any personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health conditions, sexual life or sexual orientation, or biometric or genetic data that is used to identify an individual is known as ‘special category data’. (The rest is ‘ordinary personal data’).
During the early stages of the recruitment process, we will normally only request and hold Ordinary Personal Data about you. As the recruitment process progresses, the Client may ask for certain types of Special Category Data, which will be requested from you at the time of engagement.
What type of ordinary personal data do we hold about you and why?
At the initial stages of recruitment, we collect, hold and use the following types of ordinary personal data about you:
- Information contained in your application form/CV/covering letter, including your name, title, contact details, employment history, experience, skills, qualifications/training (including educational, vocational, driving licences where appropriate), referees’ names and contact details, etc.
- Publicly available information about you, such as your business social media presence
- Selection information, including correspondence, interview notes, internal notes, the results of any written or online selection tests
If you are shortlisted for a vacancy, or you receive a conditional offer of employment, we may collect, hold and use the following additional types of ordinary personal data about you:
- Pre-employment check information, including references and verification of qualifications
- Right to work checks and related documents
We hold and use this personal data so that we can:
- process your application and correspond with you about it;
- assess whether you have the required skills, experience, qualifications and training for a role within the company;
- make informed recruitment decisions;
- verify information provided by you;
- check and demonstrate that you have the legal right to work in the UK;
- keep appropriate records of our recruitment process and decisions;
What are our legal grounds for using your ordinary personal data?
Data protection law specifies the legal grounds on which we can hold and use personal data.
We rely on one or more of the following legal grounds when we process your ordinary personal data:
- We need it to take steps at your request in order to seek work opportunities for you, because by applying for a job you are effectively asking us to represent you with our Clients.
- We need it to comply with a legal obligation e.g. the obligation not to discriminate during our recruitment process, or the obligation not to present to a Client for employment, someone who does not have the legal right to work in the UK.
- It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, it is in our legitimate interests to review and consider your personal data (as listed above) so that we can select the most appropriate candidate for the job.
How do we collect your personal data?
You provide us with most of the personal data about you that we hold and use, for example in your written application, by completing any assessments and during any interviews.
Some of the personal data we hold and use about you is generated from internal sources during the recruitment process. For example, the person interviewing you may score your suitability for the role and we record the reasons for decisions made about whether or not your application is successful.
Some of the personal data about you that we hold and use may come from external sources For example, a recruitment agency provides us with a shortlist of candidates. If we offer you a role, we will carry out pre-employment checks, such as taking up references from past employers. We may ask an occupational health professional to report to us on your fitness to do the job. In some circumstances, we may ask the Home Office for information about your immigration status to verify your right to work in the UK. For some roles, we may also obtain information about you from publicly available sources, such as your LinkedIn profile or other media sources.
Who do we share your personal data with?
Clients:
We will share your details with our Clients solely in the pursuit of suitable work opportunities on your behalf. We will inform you of the nature of the vacancy, the Client and their business as well as location, remuneration and other relevant details prior to sharing your details with a Client. At CV submission stage, we will only supply your name, approximate geographic location and your curriculum vitae (CV) to a designated recipient at the Client.
Depending on how far you progress in the recruitment process, we may, with your consent, also provide your address and contact details to facilitate the forwarding of a job offer, contract of employment or to arrange a medical examination.
We (or the Client) may also request the details of nominated referees to pursue employment/character references.
Consequences of not providing personal data
We only ask you to provide personal data that we need to enable us to make applications for suitable work opportunities on your behalf. If you do not provide particular information to us, then we will have to make a decision on whether or not to make job applications on your behalf. In addition, some of the personal data you provide to us is required by law. For example, if you do not provide us (or our Client) with the documentation we need to check your right to work in the UK, then we may not be able to find suitable employment with our Clients.
If you choose not to provide us with personal data requested, we will tell you about the implications of any such decision at the relevant time.
How long will we keep your personal data?
We will keep your personal data throughout the recruitment process and for a further period of up to 12 months from the completion of the recruitment process on your behalf.
Note, we may keep your personal data for longer than 12 months if you have asked us to consider you for future vacancies – see ‘Will we keep your application on file?’ below).
There may, however, be circumstances in which it is appropriate for us to keep particular items of your personal data for longer. We will base these decisions on relevant circumstances, taking into account the following criteria:
- the amount, nature, and sensitivity of the personal data
- the risk of harm from unauthorised use or disclosure
- the purposes for which we process your personal data and how long we need the particular data to achieve these purposes
- how long the personal data is likely to remain accurate and up to date
- for how long the personal data might be relevant to possible future legal claims
- any applicable legal, accounting, reporting or regulatory requirements that specify how long certain records must be kept
In all cases, we will not keep your personal data for longer than we need it for our legitimate purposes.
Will we keep your application on file?
If you are unsuccessful for the role for which you have applied, or you sent us a speculative application, then, if you have consented to us doing so, we will keep your personal data on file to identify if you might be suitable for any other vacancies that may arise in the next 12 months and will contact you if we believe this is the case. We will not keep your personal data for this purpose for longer than 12 months.
When applying for a particular role, there is no obligation for you to consent to us keeping your personal data on file for consideration for other roles if you do not want to. Your application for the particular role you are putting yourself forward for will not be affected.
If you change your mind about us keeping your personal data on file, you have the right to withdraw your consent at any time – see ‘Your Rights’, below.
References
If you give us details of referees, we require you to inform them what personal data of theirs you are giving to us. You must also give them our contact details and let them know that they should contact us if they have any queries about how we will use their personal data.
Your rights
You have a number of legal rights relating to your personal data, which are outlined here:
- The right to make a subject access request. This enables you to receive certain information about how we use your data, as well as to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- The right to request that we correct incomplete or inaccurate personal data that we hold about you.
- The right to request that we delete or remove personal data that we hold about you where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- The right to object to our processing your personal data where we are relying on our legitimate interest (or those of a third party), where we cannot show a compelling reason to continue the processing
- The right to request that we restrict our processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- The right to withdraw your consent to us using your personal data. As described above, we do not normally rely on your consent as the legal ground for using your personal data. However, if we are relying on your consent as the legal ground for using any of your personal data and you withdraw your consent, you also have the right to request that we delete or remove that data, if we do not have another good reason to continue using it.
- The right to request that we transfer your personal data to another party, in respect of data that you have provided where our legal ground for using the data is that it is necessary for the performance of a contract or that you have consented to us using it (this is known as the right to “data portability”).
If you would like to exercise any of the above rights, please contact Graham Vockins, Operations Director in writing. Note that these rights are not absolute and in some circumstances we may be entitled to refuse some, or all, of your request.
If you have any questions or concerns about how your personal data is being used by us, you can contact Graham Vockins, Operations Director, GenTec (graham@gentecrecruit.co.uk)
Note too that you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Details of how to contact the ICO can be found on their website: https://ico.org.uk
