Data protection officer: Iain Davies dpo@boutinot.com
As part of any recruitment process, Boutinot collects and processes personal data relating to job applicants. Boutinot is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does the organisation collect?
The organisation collects a range of information about you. This includes:
The organisation 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.
The organisation may also collect personal data about you from third parties, such as references supplied by former employers. The organisation will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does the organisation process personal data?
The organisation needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.
In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
The organisation has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.
The organisation may collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. The organisation processes such information to carry out its obligations and exercise specific rights in relation to employment.
For some roles, the organisation is obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
If your application is unsuccessful, the organisation may keep your personal data on file in case there are future employment opportunities for which you may be suited. The organisation will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
Who has access to data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the People team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with former employers to obtain references for you.
Your data may be transferred to countries outside the European Economic Area (EEA) to an external payroll agent in a situation where the post is based outside of the EEA. Data is transferred outside the EEA to the appropriate person or organisation on the basis of enabling payment of salary and other benefits in line with binding corporate rules.
How does the organisation protect data?
The organisation takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
To prevent accidental loss or destruction of personal data we have off site backups which replicate every hour meaning that we could retrieve electronic documentation if accidentally removed from the system.
Our Data Security policy states that employees must securely destroy any data that is deemed personal or confidential and the company provides shredding facilities to ensure that documentation can be correctly disposed of.
Personal data of a confidential/HR nature is held securely within a folder structure where only the relevant personnel and IT support have access.
All employees of the company have agreed to IT policies that relate to the transferring of personal data via email / portable electronic device / the cloud in order to keep company and personal data secure.
Where the organisation engages third parties to process personal data on its 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.
For how long does the organisation keep data?
If your application for employment is unsuccessful, the organisation will hold your data on file for six months after the end of the relevant recruitment process. If you agree to allow the organisation to keep your personal data on file, the organisation will hold your data on file for a further six months for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, 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 a new privacy notice.
Your rights
As a data subject, you have a number of rights. You can:
If you would like to exercise any of these rights, please contact the Data Protection Office dpo@boutinot.com
If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.
Automated decision-making
Recruitment processes are not based solely on automated decision-making.
