1. ABOUT THIS POLICY
Where you choose to apply for a role at Tructyre, we will need to process personal information about you in order to consider that application. This privacy policy is intended to help you understand the type of personal data we collect, how we use your personal information, who we share it with, and the rights you have.
If you are successful in your application our Employee Privacy Notice will apply from the point you accept our offer of employment. We will send you a copy of this together with your offer letter.
2. WHAT PERSONAL DATA WE COLLECT
During our recruitment process we will collect the following information:
• Your name;
• Your address;
• Your telephone number;
• Your email address;
• Your occupation;
• Information regarding your “right to work” in the UK;
• For certain roles, details of unspent criminal convictions;
• Information you submit as part of any job application (for example your career history, education, salary and CV);
• Information you submit as part of any optional equal opportunities questionnaire, including any self-declared disabilities;
• Any other information contained in communications between you and us;• Your responses to and results of any competency tests undertaken as part of the recruitment process;
• Information relating to you that is available in the public domain, e.g. on a LinkedIn profile; • Notes taken by those dealing with your application or interview;
• Any information provided to us by a third party in any reference.
Where we use the term personal data in this privacy policy, we are referring to all of the above.3. HOW WE USE YOUR PERSONAL DATA
We use your personal data to:
• Review and consider your application;
• To keep you up-to-date on progress and provide you with feedback (where appropriate);• For analytical, assurance and review purposes (for example by analysing your application to improve our recruitment process);
• To resolve grievances and complaints that involve you;
• In order to ensure we comply with the law in employing you;
• In relation to self-declared disabilities in order for us to make a reasonable adjustments to support your application and any possible future employment;
• To monitor our equality and diversity composition (in relation to optional equal opportunities questionnaire only).
4. LEGAL BASIS OF PROCESSING DATA
The legal basis for us processing your personal data is as follows:
• Legal Obligation: some of the personal data is processed because of a legal requirement. This includes information relating to your right to work in the United Kingdom. If you do not provide us with this information we will not be able to progress your application.
• Legitimate Interests: we consider that it is in our legitimate interests to process your personal data as part of considering your application. In particular, our legitimate interests include:o Operating a fair and transparent recruitment process;
o Resolving any complaints in a fair and transparent manner;
o Recruiting and retaining the right candidates;
o Ensuring candidates have the right skills and experience for any given role;o Ensuring that the business operates within the law in relation to the recruitment and employment of individuals.
We do not consider that our processing your personal data is likely to interfere with your fundamental rights or freedoms. However, if you object to us processing your personal data on this basis, please contact our Data Protection Officer, who will consider your objection in accordance with the relevant legal principles.
• Establishing, Exercising Or Defending Legal Claims: in exceptional cases it may be necessary for us to process your personal data (potentially including special category data) in connection with a legal claim or in response to a court order.
• Consent: in addition to the above, we consider it reasonable to believe that you have freely given consent to us receiving and processing any personal data about you which you provide to us. It is open to you to withdraw your consent at any time: if you wish to do so, please contact our Data Protection Officer.
• Criminal Offence Data: we may process criminal offence data with a view to protecting vulnerable individuals and protecting the public from dishonesty. Please refer to Processing of Special Categories of Personal Data and Criminal Offence Data Policy on page 6.
5. SPECIAL CATEGORY DATA
Special category data (sometimes called sensitive personal data) includes any information about your health, ethnic identity, political opinions, sexuality, religious/philosophical beliefs, trade union membership and genetic or biometric data.
We may process any special category data you voluntarily provide on any equality questionnaire to ensure equality of opportunity, and on the basis of your explicit consent.
We may need to process data relating to your health or racial origin in order to comply with our legal obligations relating to equality or the right to work.
Additionally, we may process any health-related special category data to assess and discuss any reasonable adjustments that may be necessary to support your application.
6. SHARING YOUR PERSONAL DATA
We may share your personal data with:
• Suppliers, service providers and partners who work with us and provide administration and support services. For example, but not restricted to candidate screening/assessment, driving licence checks and, if applicable criminal background checks
• Other group companies, who provide us with administration and support services• Government agencies and regulatory bodies where we are obliged to by law• Any third party who may acquire our business
We will usually process your personal data only in the UK. However, there may be occasions when we or our suppliers will process your data in the EU or a third country. In all cases we will ensurethat appropriate measures are put in place to keep your personal information secure and we will comply with the General Data Protection Regulation and the Data Protection Act 2018.
7. HOW WE PROTECT YOUR PERSONAL DATA
We know how important it is to protect and manage your personal data and have the following measures in place to do this:
• We use computer safeguards such as firewalls and data encryption;
• We only authorise access to colleagues who need it to carry out their job responsibilities;• We protect the security of your information while it is being transmitted by encrypting it using appropriate data transfer solutions such as Secure Sockets Layer (SSL) & HTTPS;• Where there is any doubt, we will ask for proof of identity before we share your personal data.
8. HOW LONG WE KEEP YOUR PERSONAL DATA
We will not keep your personal data longer than we need to.
In general, we keep information about unsuccessful candidates for 6 months after the conclusion of the recruitment process, although we may delete criminal records and right to work information earlier.
If you do not use your careers portal account for an extended period (usually six months from last activity), we will contact you to ask if you want to keep the account. We will contact you at least twice to ask this, and if you do not respond your account will be automatically deleted. This does not prevent you creating a new account or making any future job applications using the same email address.
9. SUBJECT ACCESS RIGHTS
You have the right to see the personal data we hold about you. This is called a Subject Access Request. If you would like a copy of the personal data we hold, please contact webcompliance@tructyre.co.uk
10. OTHER DATA PROTECTION RIGHTS
In relation to your personal data, you also have the right to:
a. Have inaccurate information corrected:
It is important that the personal data we hold on you is accurate. You also have the right to ask us to complete information you think is incomplete. If you notify us of any errors in or changes / additions to your personal data, we will update it as soon as possible.
b. Object to our use of your personal data:
If you object we will then consider your objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it (see section c below) or delete it (see section d below).
c. Restrict our use of your personal data:
There are several situations when you can restrict our use of your personal data, this includes (but is not limited to) where:
- You have successfully made an objection (listed in section b above);
- You are challenging the accuracy of the personal data we hold;
- We have used your personal data unlawfully.
d. Have your personal data deleted:
There are several situations when you can require us to delete your personal data, this includes (but is not limited to) where:
- We no longer need to keep your personal data;
- You have successfully made an objection (listed in section b above);
- We have unlawfully processed your personal data.
e. Have your personal data provided to another data controller:
Where we are processing personal data that you have provided to us solely on the basis of your consent or for the performance of a contract we have with you, you have the right to ask that we transfer that information to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
11. HOW TO COMPLAIN
If you have any concerns about our use of your personal information, you can make a complaint to us at:
Tructyre House
Princesway North
Team Valley
Gateshead
NE11 0NF
Alternatively, our Data Protection Officer can be contacted by email at webcompliance@tructyre.co.uk
You can also complain to the Information Commissioner's Office if you are unhappy with how we have used your data:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
12. CONTACT US
To contact us about this policy please email hr@tructyre.co.uk or our Data Protection Officer detailed above.
This policy replaces all previous versions and is correct as of Feb 2022. We reserve the right to change the policy at any time.
Processing of Special Categories of Personal Data and Criminal Offence Data Policy
This document outlines how Tructyre complies with the processing of special category data and criminal offence data requirements of the Data Protection Act 2018.
Data Processed
As part of your application we will process Equal Opportunities data, such as racial or ethnic origin, genetic data (such as gender), data concerning health or disability, and sexual orientation.
For a minority of roles (specifically, senior roles), we process Criminal Convictions data that you have made available in the public domain or in accordance with consent which we will obtain from you.
Condition for Processing
The conditions for processing the special categories of data under schedule 1 of the Data Protection Act 2018 are:
• your consent (including where you manifestly make such data public);
• for employment, social security and social protection; and
• to ensure and monitor equality of opportunity or treatment, including racial and ethnic diversity at senior levels.
Procedures of ensuring compliance with the principles
The personal data we collect shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed and therefore:
• We only collect personal data we actually need for our specified purposes; • We have sufficient personal data to properly fulfil those purposes;
• We periodically review the data we hold, and delete anything we don’t need. Retention and erasure policies
Applicant data (including special category and criminal offence data) is stored for a period of 6 months from the date of applying for the vacancy. An applicant may, at any time, write to hr@tructyre.co.uk to require Tructyre to cease processing and erase any personal data relating to that applicant’s racial or ethnic origin, health or sexual orientation, and Tructyre will ensure such information is erased within 14 days of receipt of such request.
Where an applicant is successful in obtaining a role at Tructyre, their data will form part of their employee personnel record and employee retention periods will be applicable to their data from their first day of employment.
Review Date: January 2023