Privacy Notice – Recruitment
Data controller: Home from Home Care Limited (Company Number: 05106283) (HFHC)
Data Compliance Officer: Steve Cranston (DCO)
- What is the purpose of this document?
HFHC is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us whether as an employee, worker or contractor. It makes you aware of how and why your personal data will be used by HFHC, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
- Data protection principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
- The kind of information HFHC will hold about you
In connection with your application for work with us, HFHC will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter
- The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications and identification documents.
- Any information you provide to us during an interview.
- We may also collect, store and use the following types of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences provided by an Enhanced DBS Check.
- How is your personal information collected?
HFHC will collect personal information about candidates from the following sources:
- You, the candidate.
- HFHC application process from which we collect data.
- Disclosure and Barring Service in respect of criminal convictions.
- IMASS Occupational Health in respect of any pre-existing health conditions that may or may not affect your working practice.
- Your named referees, from whom we collect data.
- How HFHC will use information about you
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the position.
- Carry out reference checks.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint you to the position in order to benefit our business.
HFHC also need to process your personal information to decide whether to enter into a contract of employment with you.
Having received your CV, covering letter, completed application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If HFHC decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the position. If HFHC decide to offer you the position, we will then take up references, carry out an Enhanced DBS and refer you to IMASS Occupational Health for assessment, before confirming your appointment.
- If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), HFHC will not be able to process your application successfully. For example, as we require references if you fail to provide us with relevant details, we will not be able to take your application further.
- How HFHC use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
- Information about criminal convictions
HFHC envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you a position, conditional on checks and any other conditions, such as references, being satisfactory. We are required to carry out an enhanced DBS check to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the position. In particular:
- We are legally required by CQC to carry out criminal record checks for those carrying out. The role that involves supporting vulnerable individuals is one which is listed on the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (SI 1975/1023) and is also specified in the Police Act 1997 (Criminal Records) Regulations (SI 2002/233)] so is eligible for an enhanced check from the Disclosure and Barring Service.
- The role within HFHC requires a high degree of trust and integrity since it involves supporting vulnerable individuals and so we would like to ask you to seek an Enhanced DBS.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
- Automated decision-making
You will not be subject to decisions that will have a significant impact on you based on automated decision-making.
- Data sharing
- Why might you share my personal information with third parties?
HFHC will only share your personal information with the following third parties for the purposes of processing your application: Disclosure Barring Service and IMASS Occupational Health. All our third-party service providers and other entities in our group are required to take appropriate security measures to protect your personal information in line with our policies. HFHC do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with HFHC’s instructions.
- Data security
HFHC have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
- Data retention
- How long will you use my information for?
If you are successful and become an employee of HFHC, we will retain your personal information for the period that you are employed by HFHC in accordance with the terms of our Employee Privacy Notice. If unsuccessful post interview stage, HFHC will retain your personal information for a period of at least 6 months so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations. If you make an application for employment at HFHC and you are not shortlisted for interview, we will not retain your information.
If HFHC wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
- Rights of access, correction, erasure, and restriction
- Your rights regarding personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information commonly known as a “data subject access request”. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information HFHC hold about you corrected.
- Request erasure of your personal information. This enables you to ask HFHC to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask HFHC to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask HFHC to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DCO in writing.
- Right to withdraw consent
You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the DCO. Once we have received notification that you have withdrawn your consent, HFHC will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
18. Data Compliance Officer
HFHC have appointed a Data Compliance Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how HFHC handle your personal information, the DCO can be contacted by email at firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
This privacy notice may change from time to time so we recommend that you review it periodically. This version of the privacy notice was last updated on 5th June 2018.