Application and Recruitment policy - DAC Beachcroft

Application and Recruitment policy

 

INTRODUCTION

DAC Beachcroft is committed to protecting the data of its job applicants.  This Notice sets out important information about how DAC Beachcroft collects and uses your data during the course of the application and recruitment process. For the purpose of this Notice, such reference to “data” means your personal data, special categories of personal data and/or personal data relating to criminal convictions and offences. 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).

 

SCOPE

This Notice applies to all job applicants.

 

WHAT DATA DO WE COLLECT?

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. 

Personal data means information which identifies you and relates to you as an individual. We have set out below the main categories of candidate 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;
  • gender; and/or
  • 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 data to be provided by you is mandatory in connection with our recruiting activities. Failure to provide mandatory 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 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 data which are processed.

Whilst the majority of the data which we process will be collected directly from you, your 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; and/or
  • 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 DATA?

DAC Beachcroft uses your 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 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; and/or
  • for the purposes of conducting data analytics to review and better understand the operation of our recruitment processes.

In addition to using your data to consider you for the role you applied for, we will retain and process your 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.

Certain categories of data are considered "special categories of personal data" and are subject to additional safeguards. DAC Beachcroft limits the special categories of 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 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 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 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 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.

Again, the lists above are not exhaustive and DAC Beachcroft may undertake additional processing of 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 data.

 

WHEN DO WE SHARE DATA?

DAC Beachcroft may, as follows, share data with other parties in certain circumstances and where it is necessary to achieve the purposes detailed above:  

  • 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; and/or
  • our regulators.

As we are a global employer, data may be transferred outside of the UK and the European Economic Area ('EEA').  For example this may be to share your data with other group companies from time to time for the purposes to set out in this Notice. In particular, DAC Beachcroft may share your 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, your data is shared where appropriate technical and organisational measures are in place to protect that data in line with this Notice and also our obligations or as permitted by applicable law and/or regulation.

 

FOR HOW LONG WILL MY DATA BE RETAINED?

DAC Beachcroft's policy is to retain 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 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 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 data to be maintained on file for this purpose, please inform us.
  • If you are offered and accept employment with us, the 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 and Member Privacy Notice.

 

WHAT ARE MY RIGHTS IN RELATION TO MY DATA?

DAC Beachcroft will always seek to process your 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 data, to object to particular aspects of how your data is processed, and otherwise to seek the restriction of the processing of your data.  You also have the right to request the transfer of your 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 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 data is being processed with:

  1. 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 casework@ico.org; or
  2. 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 info@dataprotection.ie.
  3. Spain: 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.
  4. France: The Commission nationale de l'informatique et des libertés (CNIL) by going to CNIL’s website: https://www.cnil.fr/ or by contacting CNIL on +33 (0) 1 53 73 22 22.

We have elected the DPC as our Lead Supervisory Authority within the EU.

In addition to our designated Lead DPO for the UK, we have appointed a Lead DPO for the EU.

 

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 dataprotectionenquiryteam@dacbeachcroft.com or by post to:

Data Protection Enquiry Team
DAC Beachcroft
St Paul's House
23 Park Square South
Leeds
United Kingdom
LS1 2ND

 

Last updated: October 2020