Application and Recruitment policy
DAC Beachcroft is committed to protecting the personal data of its job applicants. This Notice sets out important information about how DAC Beachcroft collects and uses your personal data during the course of the application and recruitment process. DAC Beachcroft has a global Notice that we follow based on European data protection principles.
DAC Beachcroft is an international legal business which operates through separately constituted and regulated legal entities providing legal and/or claims handling services in accordance with the relevant laws of the jurisdictions in which the different entities operate.
The use of words and/or phrases such as "DAC Beachcroft", "we", "us" or "our" is for convenience only and refers to any of the entities listed in our Legal Notice, each of which is a separate data controller in their own right.
You should read this Notice carefully and raise any questions you may have with the Data Protection Enquiry Team (outlined below in this Notice).
This Notice applies to all job applicants.
WHAT PERSONAL DATA DO WE COLLECT?
Personal data means information which identifies you and relates to you as an individual. As your prospective employer, DAC Beachcroft will collect, use and store your personal data for a wide variety of reasons in connection with the application and recruitment process. We have set out below the main categories of candidate personal data which we process in connection with our recruiting activities on a day to day basis:
- personal contact information (including your name, home address, personal telephone number(s) and/or personal e-mail address);
- work history and other relevant experience including information contained in CV, cover letter and/or job application form;
- education information including degrees awarded, transcripts and other information provided in support of the job application;
- compensation history;
- information collected during phone screenings and/or interviews;
- details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and/or benefits;
- reference information and information received from background checks (where applicable) including information provided by third parties;
- information related to previous applications to us or previous employment history with us;
- documents evidencing your right to work (including information about your immigration status where relevant);
- date of birth;
- information gathered through DAC Beachcroft's monitoring of its IT systems, building access records and CCTV recording in relation to your communications with us and/or attendance at our premises.
The majority of the personal data to be provided by you is mandatory in connection with our recruiting activities. Failure to provide mandatory personal data may affect our ability to accomplish the purposes stated in this Notice, including considering your suitability for employment and/or entering into an employment contract with you.
The list set out above is not exhaustive, and there may be other personal data which DAC Beachcroft collects, stores and uses in the context of the application and recruitment process. DAC Beachcroft will update this Notice from time to time to reflect any notable changes in the categories of personal data which are processed.
Whilst the majority of the personal data which we process will be collected directly from you, your personal data may also be provided to us by third parties, such as recruitment agencies, former employers, official bodies (such as regulators or criminal record bureaus), medical professionals and/or LinkedIn.
REFERENCING AND VETTING
As part of our referencing and vetting procedures, we may contact certain third parties in order to verify your personal information (including personal information that you provide as part of the application and recruitment process). These third parties may include:
- former employers in order to verify your previous employment history (this may include contacting your current or former accountants where you are or were self-employed or an agency where you were paid through the agency);
- universities and/or other establishments for higher education that you attended in order to verify your education history;
- other institutes in order to verify other qualifications (such as CIPD);
- verification agencies to verify your credit reference, directorships, identification and criminal record checks;
- professional bodies in order to verify membership.
We will only seek this information in relation to successful candidates that have accepted a conditional offer of employment with us and we will specifically inform such candidates that we will be contacting these third parties in advance of doing so.
HOW DO WE USE YOUR PERSONAL DATA?
DAC Beachcroft uses your personal data for a variety of purposes in order to take steps necessary to enter into an employment contract with you, to comply with legal obligations or otherwise in pursuit of its legitimate business interests. We have set out below the main purposes for which candidate personal data is processed:
- to identify and evaluate job applicants, including assessing skills, qualifications and experience;
- verifying candidate information and carrying out employment, background and reference checks, where applicable and in order to prevent fraud;
- communicating with you about the recruitment process and your application;
- to comply with our legal, regulatory, or other corporate governance requirements;
- for the purposes of conducting data analytics to review and better understand the operation of our recruitment processes.
In addition to using your personal data to consider you for the role you applied for, we will retain and process your personal data to inform you about and to consider you for other roles that may be appropriate for you. If you do not want us to consider you for other roles which we consider may be appropriate for you, please inform your HR contact.
Again, this list is not exhaustive and DAC Beachcroft may undertake additional processing of personal data in line with the purposes set out above. DAC Beachcroft will update this Notice from time to time to reflect any notable changes in the purposes for which its processes your personal data.
WHAT SPECIAL CATEGORIES OF PERSONAL DATA DO WE PROCESS?
Certain categories of data are considered "special categories of personal data" and are subject to additional safeguards. DAC Beachcroft limits the special categories of personal data which it processes as follows:
- Health Information
We may process information about a candidate's physical or mental health in compliance with our obligations owed to disabled employees.
We will always treat information about health as confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.
If a candidate is successful, any health information processed as part of the recruitment process that is relevant to DAC Beachcroft's compliance with its obligations in connection with employment will be retained and processed in accordance with the Employee Privacy Notice.
If a candidate is unsuccessful, any health information obtained as part of recruitment process will be deleted with the rest of the candidate's personal data within 15 months of their rejection subject to any exceptional circumstances and/or to comply with particular jurisdictional laws and/or regulations and/or business continuity purposes.
- Criminal Record Information
Given the nature of our business, we ask successful candidates who have accepted a conditional offer of employment to disclose their criminal record history and we carry out criminal record checks as part of our background vetting process and in compliance with our obligations in connection with employment.
We will always treat criminal record history as confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure.
Criminal record information will be deleted once the recruitment process has been completed, subject to any exceptional circumstances and/or to comply with particular laws or regulations. Criminal record information will be retained in accordance with our information retention and destruction policy, although the outcome of any check will remain on the employee's record. Criminal record information will typically be retained for a maximum of 15 months, although the outcome of any check will remain on the employee's record.
- Equal Opportunities Monitoring
DAC Beachcroft is committed to providing equal opportunities for employment and progression to all of its employees and from time to time it will process information relating to ethnic origin, race, nationality, sexual orientation and disability, alongside information relating to gender and age, for the purposes of equal opportunities monitoring.
We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorised access, use, alteration, or disclosure. In addition, this monitoring will always take place in accordance with appropriate safeguards as required under applicable law, including:
- the provision of information relating to ethnic origin, race, nationality, sexual orientation and disability for the purposes of monitoring will be voluntary and processed for this purpose only with your consent;
- wherever possible, the monitoring will be conducted on the basis of using anonymised data so individual candidates cannot be identified; and/or
- the information processed for monitoring purposes will be maintained separately from general management and HR records.
WHEN DO WE SHARE EMPLOYEE PERSONAL DATA?
DAC Beachcroft will share employee personal data with other parties only in limited circumstances in order to take steps necessary to enter into the employment contract or where necessary to comply with a legal obligation, or otherwise in pursuit of its legitimate business interests as follows:
- recruitment agencies;
- background vetting specialists;
- occupational health providers;
- HMRC (in the UK), Revenue (in Ireland) and/or any other applicable government body;
- accountants, lawyers and other professional advisers;
- The Solicitors Regulation Authority, The Law Society of England and Wales, The Law Society of Scotland and the Law Society of Ireland.
Unless required by the law and/or regulation, in all cases employee personal data is shared under the terms of a written agreement between DAC Beachcroft and the third party which includes appropriate security measures to protect the personal data in line with this Notice and our obligations. The third parties are permitted to use the personal data only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission.
As a global employer, DAC Beachcroft will also share employee personal data with other group companies from time to time for the purposes to set out in this Notice. In particular, DAC Beachcroft shares employee personal data with other group companies for the purposes of support with employee administration and the management of participation in the employee stock plan and related benefits.
In all cases, where personal data is transferred to a country which is deemed not to have the same level of protection for personal data as the home country in the European Economic Area ("EEA"), DAC Beachcroft has put in place written data transfer agreements to protect the personal data. In the case of any transfer of personal data from a country within the EEA to a country outside of the EEA, these transfer agreements incorporate the standard contractual clauses approved by the European Commission. If you have any questions about the transfer of your personal data in these circumstances, please contact our Data Protection Enquiry Team (outlined below in the Notice).
FOR HOW LONG WILL MY PERSONAL DATA BE RETAINED?
DAC Beachcroft's policy is to retain personal data only for as long as needed to fulfil the purpose(s) for which it was collected, or otherwise as required under applicable jurisdictional laws and/or regulations and/or business continuity purposes. Under some circumstances we may anonymise your personal data so that it can no longer be associated with you. We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice to you.
For unsuccessful candidates:
- We will typically retain personal data collected during the recruitment process for a maximum period of 15 months from the end of the process subject to any exceptional circumstances and/or to comply with particular jurisdictional laws and/or regulations and/or business continuity purposes.
- We may retain select data relating to particular candidates on file for a longer period than 15 months in order to follow up with the candidates in relation to future vacancies; if you do not wish for your personal data to be maintained on file for this purpose, please inform us.
If you are offered and accept employment with us, the personal data we collected during the application and recruitment process will become part of your employment record and we may use it in connection with your employment in accordance with our Employee Privacy Notice.
WHAT ARE MY RIGHTS IN RELATION TO MY PERSONAL DATA?
DAC Beachcroft will always seek to process your personal data in accordance with our obligations, our rights and your rights.
You will not be subject to decisions based solely on automated data processing without your prior consent.
In certain circumstances, you have the right to seek the erasure or correction of your personal data, to object to particular aspects of how your data is processed, and otherwise to seek the restriction of the processing of your personal data. You also have the right to request the transfer of your personal data to another party in a commonly used format. If you have any questions about these rights, please contact our Data Protection Enquiry Team (outlined below in the Notice).
You have a separate right of access to your personal data processed by DAC Beachcroft. You may be asked for information to confirm your identity and/or assist DAC Beachcroft to locate the data you are seeking as part of DAC Beachcroft's response to your request. If you wish to exercise your right of access, please contact our Data Protection Enquiry Team (outlined below in the Notice).
Given the location of our European offices, if you are an individual located in the EU you have the right to raise any concerns about how your personal data is being processed with:
- UK: the Information Commissioner's Office (ICO) by going to the ICO's website: https://ico.org.uk/concerns/ or contacting the ICO on 0303 123 1113 or firstname.lastname@example.org; or
- Ireland: the Data Protection Commissioner (DPC) by going to the DPC's website: https://dataprotection.ie/docs/complaints/1592.htm or by contacting the DPC on 1890 25 22 31 or email@example.com.
- Madrid: Spanish Data Protection Agency/Agencia Española de Protección de Datos ("AEPD") by going to the AEPD's website: https://www.agpd.es/portalwebAGPD/index-iden-idphp.php or by contacting the AEPD on 901 100 099 – 912 663 517.
WHERE CAN I GET FURTHER INFORMATION?
If you have any questions about this Notice, want to exercise your right to see a copy of the information that we hold about you, or think that information we hold about you may need to be corrected, want to delete all or any part of it or to object to the processing on legitimate grounds, please contact us by email on firstname.lastname@example.org or by post to:
Data Protection Enquiry Team
St Paul's House
23 Park Square South
Last updated: May 2018