JOB APPLICANT PRIVACY NOTICE

Data controller: Way To Blue Ltd, 63 Gee Street, London, EC1V 3RS.
Telephone: +44 (0)20 7749 8444

Data protection officer: Marc Berry Reid, Chief Operating Officer.
Contact: compliance@waytoblue.com

As part of any recruitment process, Way To Blue collects and processes personal data relating to job applicants. Way To Blue is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does Way To Blue collect?

Way To Blue collects a range of information about you. This includes:

• Your name, address and contact details, including email address and telephone number;
• Details of your qualifications, skills, experience and employment history;
• Information about your current level of remuneration, including benefit entitlements;
• Whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
• Information about your entitlement to work in the UK; and

Way To Blue may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or covering letters, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

Way To Blue may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. Way To Blue 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 Way To Blue process personal data?

Way To Blue needs to process data to take steps at your request prior to entering into a contract with you.

In some cases, Way To Blue 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.

Way To Blue 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 Way To Blue to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.

Way To Blue may process information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability.

For some roles, Way To Blue is obliged to seek information about criminal convictions and offences. Where Way To Blue 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.

Way To Blue will not use your data for any purpose other than the recruitment exercise for which you have applied. However, if your application is unsuccessful, Way To Blue may keep your personal data on file in case there are future employment opportunities for which you may be suited. Way To Blue will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Where do we get your data from?

Way To Blue may receive your personal data from a third party recruiter who run the recruitment process. Occasionally Way To Blue or the third party recruiter may obtain your personal data from publicly accessible sources e.g. LinkedIn.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR 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 any other third parties except those stated above, unless your application for employment is successful and it makes you an offer of employment. Way To Blue will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

Way To Blue will not transfer your data outside the European Economic Area.

How does Way To Blue protect data?

Way To Blue 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. We use a cloud-based system to store your data that requires 2 factor authentication. Only relevant members of the HR/recruitment team have access to the email account which receives all applications from candidates.

Where Way To Blue engages 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 measures to ensure the security of data.

For how long does Way To Blue keep data?

If your application for employment is unsuccessful, Way To Blue will hold your data on file for 6 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 6 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 employee 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:

• Access and obtain a copy of your data on request;
• Require the organisation to change incorrect or incomplete data;
• Require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
• Object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights, please contact compliance@waytoblue.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.