Fasthosts: Data protection privacy notice for recruitment using Teamtailor
The service for handling recruitment and simplifying the hiring process is powered by Teamtailor (‘Service') on behalf of Fasthosts Internet Limited trading as Fasthosts (‘Company’). 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 recruitment 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
The Company is a data controller and gathers and uses certain information about you. References in this notice to ‘we’ or ‘us’ means the Company. We are responsible for your personal data collected and processed in accordance with this Privacy Notice.
Data protection principles
We will comply with the data protection principles when gathering and using your personal information. This means that we will:
(i) Use your personal data lawfully, fairly and in a transparent way;
(ii) Collect it only for valid purposes as made clear to you;
(iii) Ensure your personal data held by us is relevant to the purposes for we have told you about and not use it for any other reason;
(iv) Ensure we only hold your personal data for as long as is necessary to carry out the purpose of the processing; and
(v) Keep your personal data secure
About the information we collect and hold
This notice covers any personal data you submit or share with us as part of our
recruitment process.
Part A of the Schedule below summarises the information we collect and hold (up to and including the shortlisting stage) during the recruitment process, how and why we do so, how we use it, and with whom it may be shared.
Part B of the Schedule below summarises the additional information we collect before making a final decision to recruit, 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 the information we collect or to the purposes for which we collect and process it.
We carry out basic criminal convictions checks on candidates for a small number of specific roles in our Company. We do this on the basis that these roles require a high level of trust and integrity, as they deal with high value assets of the Company and high volumes of customer data. It is also a requirement of our security accreditation. These checks will only be carried out at the point an offer of employment has been made and will only include details of any unspent convictions.
We will only process criminal convictions data when required or permitted by law, or when you have provided your consent to do so. As required by law, we have in place an appropriate policy, which is available upon request.
How we may share your information
We may need to share some of the information set out in Parts A and B below with other parties, such as HR consultants, professional advisers, and providers of background and reference-checking services. The recipient will be bound by confidentiality obligations. We may also be required to share some personal information as required by law.
Where information may be held
Information may be held at our offices in the UK and those of our group companies, which are based in the EU, and third party agencies, service providers, representatives and agents. Where background screening (including criminal convictions checks) are carried out by our third party provider, this may require data being transferred outside of the UK and EU. Where this is the case, we will take steps to ensure your personal data is transferred securely and in accordance with data protections laws.
How long do 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 a minimum 6 months, and no longer than is reasonable, taking into account 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 keeping recruitment records for longer than the recruitment period, we may do so but only with your consent, you have the right to withdraw consent at any time by contacting the Company using the contact details of the Data Protection Officer (DPO) listed below If your application is successful, we will keep the recruitment information that is necessary in relation to your employment.
Cookies
When you use the Service, information about the usage may be stored as cookies. Cookies are passive text files that are stored in the internet browser on the User’s device, such as computer, mobile phone or tablet, when using the Service. We use cookies to improve your usage of the Service and to gather information about, for example, statistics about the usage of the Service. This is done to secure, maintain and improve the Service. The information that is collected through the cookies can in some instances be personal data and is, in such instances, regulated by our Cookie Policy, which can be found on our website.
Users can at any time disable the use of cookies by changing the local settings in their devices. Disabling cookies can affect the experience of the Service, for example disabling some functions in the Service.
Your right to object to us processing your information
Where our processing of your information is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your information unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
Please contact our Data Protection Officer (DPO), who can be contacted via email privacy@fasthosts.com if you wish to object in this way.
Your rights to correct and access your information and to ask for it to be erased
Please contact our Data Protection Officer (DPO), who can be contacted via privacy@fasthosts.com if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask our Data Protection Officer for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. Our Data Protection Officer will provide you with further information about the right to be forgotten if you ask for it.
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 here we are legally required to do so.
Changes
We have the right to, at any time, make changes or additions to this Privacy Notice. The latest version of the Privacy Notice will always be available through the service. Where appropriate, we will notify you of any changes by email or when you next visit the Services’ website.
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 at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
THE SCHEDULE
INFORMATION WE COLLECT AND HOLD
Part A - Up to and including the shortlisting stage
The Information we collect
1. Your name and contact details (ie address, home, and mobile phone numbers,
email address)
How we collect the information:
From you directly, from our existing employees, from job boards, and from you via our service providers
Why we collect the information:
(i) Legitimate interest: to carry out a fair recruitment process
(ii) Legitimate interest: to progress your application, arrange interviews and inform you of the outcome at all stages
How we use and may share the information:
(i) 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
(ii) To inform the relevant manager or department of your application
2. Details of your qualifications, experience, employment history (including salary and job titles) and interests. Your curriculum vitae, photos and videos, and answers to questions as part of the recruitment process. Information from social media accounts and the emails you send to us.
How we collect the information:
(i) From you directly
(ii) From publicly available social media sites
Why we collect the information:
Legitimate Interests to carry out a fair recruitment process and to make an informed decision to shortlist for interview.
If you are unsuccessful in your application, your details may be passed on associated company to see if they have any vacancies
How we use and may share the information:
(i) To make an informed recruitment decision.
(ii) The person making the shortlisting decision will receive pseudonymised details only.
(iii) To see whether an associated company has any suitable vacancies
3. Details of your referees
How we collect the information:
From you
Why we collect the information:
Legitimate interest: to carry out a fair recruitment
How we use and may share the information:
To carry out a fair recruitment process. Information shared with relevant managers, HR personnel and the referee.
If your application is unsuccessful at this stage, we will keep your information (in pseudonymised form), for the purpose of establishing, exercising, and or defending any legal claims, in accordance with our legitimate interests.
PART B: Before making a final decision to recruit
The information we collect:
1. Information about your previous academic and/or employment history, including any 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 information:
From you or your referees
Why we collect the information:
Legitimate Interests to make an informed decision to recruit, to maintain employment records and to comply with good employment practice.
How we use and may share the information:
To obtain the relevant reference about you. Information shared with relevant managers and HR personnel.
2. Your name, email address and results of criminal conviction background screening checks
How we collect the information:
From you and our background check third party supplier.
Why we collect the information:
Legitimate Interests to make an informed decision to recruit candidates for specific roles involving security compliance requirements and high levels of trust and integrity.
We process this personal data on the grounds of substantial public interest, for the purposes of the prevention and detection of unlawful acts. We have our appropriate policy document in place, which is available upon request.
How we use and may share the information:
To carry out Criminal Record checks which are required for certain roles in the Company. Information shared with third party provider of background and criminal checking services.
3. Your nationality and immigration status and information from related documents, such as your passport or other identification information
How we collect the information:
From you
Why we collect the information:
(i) To enter into/perform the employment contract
(ii) To comply with legal obligations
(iii) Legitimate interest: To maintain employment records
How we use and may share the information:
(i) To carry out right to work checks
(ii) Information may be shared with the Home Office
4. Information relating to your health
How we collect the information:
From you
Why we collect the information:
(i) To comply with our legal obligations
(ii) Legitimate Interests: To ensure you are fit to perform the duties and to make any adjustments which may be required for interviews or assessments. As your health data is classed as a special category of data, we have in place an appropriate policy document, which is available upon request. This explains that we need to process this data in order to comply with our employment and social security legal obligations.
How we use and may share the information:
To make an informed recruitment decision.
If your application is unsuccessful at this stage, we will keep your information for a minimum of 6 months, for the purpose of establishing, exercising and/or defending any legal claims, in accordance with our legitimate interests.
We may also keep your information with your consent, for any roles that we may believe would be of interest to you in the future.