1. Who collects the information
nkoda Limited is a ‘data controller’ and gathers and uses certain information about you.
2. What information is gathered and held
We may collect the following information up to and including the shortlisting stage of the recruitment process:
- your name and contact details (i.e. address, home and mobile phone numbers, email address);
- details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests;
- your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs;
- information that you voluntarily provide through the recruitment process.
We may collect the following information after the shortlisting stage, and before making a final decision to recruit:
- information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers;
- information regarding your academic and professional qualifications;
- your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
- details of your referees and the references given;
- your written responses to any tests we give you as part of the recruitment process;
- any further information that you voluntarily provide through the recruitment process.
At the relevant time, we will let you know what further information we required to complete the recruitment process.
As a general rule, during the recruitment process, we try not to collect or process any of the following: information that reveals your racial or ethnic origin; religious, political or philosophical beliefs; trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health or sex life (categorised under the data protection legislation as sensitive personal information), unless authorised by law or necessary to comply with the law.
However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some sensitive personal information for legitimate recruitment-related purposes. For example, information about your race or ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws; to comply with government reporting obligations, or to consider what adjustments may be needed to be made to the recruitment process and your subsequent role.
3. How we collect the information
We may collect this information from you, your referees (details of whom you will have provided), your education provider, the relevant professional body, the recruitment agency we are using and the Home Office.
4. Why we collect the information and how we use it
We will typically collect and use this information primarily for recruitment purposes. We use it to assess your skills, to determine your qualifications and background, to verify the information you have provided and to generally manage the hiring process and communicate with you.
With specific regard to the data protection legislation we use the information for the following purposes:
- to take steps to enter into a contract;
- for compliance with a legal obligation;
- for the purposes of our legitimate interests or those of a relevant third party (such as a benefits provider), but only if these are not overridden by your interests, rights or freedoms;
- because it is necessary for carrying out obligations or exercising rights in employment and immigration law;
- for reasons of substantial public interest (i.e. equality of opportunity or treatment, preventing or detecting unlawful acts); and
- to establish, exercise and/or defend any legal claims that may be brought by or against us in connection with your recruitment.
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.
5. How we may share the information
We take care to allow access to personal information about you to only those persons who require access to perform their tasks and duties. We may also need to share your personal information with other parties, such as HR consultants and professional advisers, taking steps to ensure that the security and confidentiality of the information are maintained. Usually, the information will be anonymised but this may not always be possible. We may also be required to share some personal information as required to comply with the law.
6. Where information may be held
Information may be held at our offices and third-party agencies, service providers, representatives and agents as described above.
7. How long 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 no longer than is reasonable, taking into account the limitation periods for potential claims such as 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 will first consider whether the records can be pseudonymised, and the longer period for which they will be kept.
If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment.
8. 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 us at firstname.lastname@example.org if you wish to object in this way.
9. Your rights to correct and access your information and to ask for it to be erased
Please contact us at email@example.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 us for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. We will provide you with further information about the right to be forgotten, if you ask for it.
10. 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 where we are legally required to do so.
11. How to complain
We hope that we 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.