Job Applicant Privacy Notice

Policy version 1.0.0 as of 25/05/2018

Distribution Technology is committed to the privacy of its potential future employees, contractors/workers, and this Privacy Notice sets out how and why your personal data is collected. It also describes how your personal data is processed in a fair and transparent manner in line with Data Protection Laws such as the UK Data Protection Act 2018 (“DPA”) and the EU General Data Protection Regulation 2016 (“GDPR”) or their supplants.

We may need to make changes to this policy from time to time, so please regularly review this policy which is available on our website:-

https://legal.distribution-technology.com/policies/JobApplicantPrivacyNotice.html

Within this policy Distribution Technology is collectively referred to as "we", "us" or "our”.

By providing personal data you consent to this Privacy Policy.

Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions or concerns about your data privacy or this Privacy Notice, including any requests to exercise your legal rights, please contact either the People Team or Mark Rowson who is our DPO:

FAO Data Protection Officer
Distribution Technology Ltd.
Sovereign House
Vastern Road
Reading
Berkshire
RG1 8BT

DPO@Distribution-Technology.com
Tel: 0333 6000 500

You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK Supervisory Authority (“SA”) for data protection issues (https://www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

It is important that the personal data we hold is accurate and current. Please keep us informed if any personal data changes during your relationship with us.

When this notice applies

This policy applies to all job applicants of Distribution Technology Ltd. We collect and processes personal data relating to job applicants in order to manage the recruitment and selection process. We are committed to being transparent about how we collect and use this data and meeting our data protection obligations under the applicable data protection legislation.

Privacy of others

You may need to provide us with another person’s personal data – e.g. previous employers contact details for reference checks You will need to inform the individual what personal data of theirs you are giving to us. You must also give them our contact details and let them know that they should contact us if they have any queries about how we will use their personal data.

The data we collect about you

Personally Identifiable Information (PII), means any data that could identify a specific individual or natural person. Personal Data means any information relating to an identified living individual or natural person (“Data Subject”) who can be identified directly or indirectly in reference to an identifier or to one or more specific factors.

When such data is collected, used, stored or transferred, we will ensure that it is relevant and limited to what is necessary for the purposes.

We collect and process a range of information about you. This includes:

How is your personal data collected?

We may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests where requested.

We may also collect personal data about you from third parties including recruitment agencies, social media and career sites. In addition, references supplied by former employers, educational establishments or personal referees, information from employment background check providers and information from criminal records checks as part of our pre-employment screening process. We will seek information from third parties for pre- employment screening purposes only once a job offer to you has been made and will inform you before doing so.

We are obliged to seek information about criminal convictions and offences in accordance with our Screening and Vetting Policy. Where we seek this information, it is because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment. Should we wish to make you a job offer, a copy of our Screening and Vetting Policy will be provided.

Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (such as those in relation to employees with disabilities).

Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this will be for equal opportunities monitoring purposes.

Additionally, when entering our offices, site access information about you will also be collected such as CCTV and visitor logs.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

We may process information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.

We will not use your data for any purpose other than the recruitment exercise for which you have applied. However, if your application is unsuccessful, the organisation may wish to keep your personal data on file for 12 months in case there are future employment opportunities for which you may be suited. You are free to withdraw your consent at any time.

Basis for lawful processing

We have identified the following as normal lawful basis on which we will process your personal data:-

Disclosures of your personal data

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the People and Recruitment team, interviewers involved in the recruitment process including managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

We will not share your data with third parties unless your application for employment is successful and we make you an offer of employment. We share your data with third parties in order to obtain pre-employment references from other employers, administer employment background checks from third-party providers including necessary criminal records checks from the Disclosure and Barring Service. Where we use a third party to administer these checks you will be invited to upload your information directly and give express consent, via the third party to enable the checks to be carried out.

If we need to share information about you which is deemed to be special category information outside of the organisation, we will seek consent before passing this on.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Sub processors & international transfers

During your application we will need to share some of your personal data with the following organisations in order to progress your application and when we do, this will be limited to the minimum necessary:-

Experian Ltd.
Pre-employment background checks such as identity, adverse financial, criminal record and reference validation.
https://www.experian.co.uk/background-checking/pre-employment-screening.html

We will not transfer or store your personal data outside the European Economic Area (EEA) without your consent.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an un-authorised way, altered or disclosed.

We take the security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by certain employees in the performance of their duties.

Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, compliance, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will hold your applicant data on file for 12 months after the end of the relevant recruitment process and for consideration for future employment opportunities. At the end of that period your data is deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in an Employee Privacy Notice which you will need to read and accept.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, such as:

Subject Access Request (SAR)

If you wish to exercise any of these rights, please contact our Data Protection Officer as detailed at the top of this policy. It will help us to process your request without delay if you complete our SAR form which you can download from the link below and either post it or email it to us.

https://legal.distribution-technology.com/docs/SAR-Form.pdf

There is no charge for an individual SAR. However, multiple copies or excessive repeat requests may be charged a reasonable fee based on administration costs.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. Details of how to provide acceptable proof of identity are included in our SAR form. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will respond to all requests within 30 days. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Depending on how you have submitted your SAR it may be impractical for us to respond in the same way due to technical or security constraints. In this case we may ask you for a more appropriate method of address.

What if you do not provide personal data?

You have some obligations under your employment contract to provide us with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide us with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.

Certain information, such as contact details, your right to work in the UK and payment details, have to be provided to enable us to enter a contract of employment with you. If you do not provide other information, this will hinder our ability to administer the rights and obligations arising as a result of the employment relationship efficiently.

Automated decision-making

Employment decisions are not based solely on automated decision-making.