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Title: Data Privacy Notice (Candidates)Author: Ally Boulton (Chief of Staff) and Elaine Yersin (Information Governance Manager)Responsible Person: Ally Boulton (Chief of Staff)
Operational Responsible Person: Steve Scott (Chief of Recruitment)
Department: CEO Office
Authorised: Bahman Nedjat-Shokouhi (CEO)
Issue Date: November 2022
Review Date: November 2025
Who does this policy apply to? All individuals who apply for a role working at Medefer. This includes contractor roles and employee roles.
Compliance Monitoring (Audit/spot checks): Weekly TeamTailor data notifications, CQC Inspection, spot checks, Data Security and Protection Toolkit.
Training & Communication: All Recruitment Team members are shown how to access the policy as well as how to action and update data requests within the platform.
All concerns should be directed to firstname.lastname@example.org.
Policy locations and references: BreatheHR, TeamTailor, Radar
Keywords: Privacy, Data Protection, Sensitive Information, Personal Information
Revision date: December 2022
Approved by: Bahman Nedjat-Shokouhi
Summary of changes: New policy
Medefer Limited is a data controller in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.
1. Aim of this Policy
The aim of this policy is to ensure that candidates and new employees at the Company understand how their personal data is used and the process under which it is protected. The policy also informs the candidates of their rights in connection with personal information.
There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.
Roles and Responsibilities
Data Protection Officer
We have appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer (email@example.com) You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) who is responsible for data protection issues in the UK.
The Medefer Recruitment Team are responsible for ensuring that any TeamTailor data requests are actioned in line with this policy alongside any requests made through other channels.
4. Policy Information
Data protection principles
Medefer will comply with data protection law and principles. This says that the personal information we hold about you must be:
The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following personal information about you:
We may also collect, store and use the following types of more sensitive personal information:
How is your personal information collected?
We collect personal information about candidates through the application and recruitment process from the following sources:
How we will use information about you
We will use the personal information we collect about you to:
We also need to process your personal information to decide whether to enter into a contract with you.
Having received the information provided to us and collated by and for us during the recruitment process (including any test results) we will then process that information to decide whether you meet the basic requirements to be shortlisted for the work. 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 work. If we decide to offer you the work, we will then take up references and/or carry out a criminal record check and/or carry out any other check as required before confirming your appointment.
If you fail to provide personal information
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 we use particularly sensitive personal information
We will use your sensitive personal information in the following ways:
Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with policies.
We hold information about criminal convictions in line with the Medefer DBS policy.
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences and apply for DBS checks, prior to the commencement of employment.
We are allowed to use your personal information in this way to carry out our obligations. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application: All our third-party service providers and other entities 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 data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Medefer has 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.
We have put in place policies and procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to appoint you to work. 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 against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our Records Management Policy. If you are a successful candidate, information will be used to create your personnel file and retained in line with our Retention and Disposal Policy and national guidance.
Rights of access, correction, erasure, and restriction
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact firstname.lastname@example.org
Right to withdraw consent
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact email@example.com or request to be deleted via your TeamTailor Candidate account. 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 data securely. When a request is made via TeamTailor, your data will automatically be removed from the system within a 7-day period.
6. External bodies
7. External References and Associated Medefer Documents
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