Bettys & Taylors Group Ltd  

Privacy Notice for Candidates

Version 2.0, 20.02.2023

What is the purpose of this document?

Bettys & Taylors Group Ltd is committed to protecting the privacy and security of your personal information. This privacy notice applies to all candidates (whether you are applying to work with us as an employee, worker or consultant) and describes how we collect and use personal information about you during the recruitment process, and how long it will be retained for, in accordance with the General Data Protection Regulation (GDPR). This includes any information that you submit to our online recruitment software and any information gathered through our website.

Bettys & Taylors Group Ltd is a "Data Controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

 

What is Personal Data?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are "special categories" of more sensitive personal data which require a higher level of protection.

The kind of information we hold about you

We may collect, store and use the following categories of personal information about you:

• Name.
• Address and contact details, including email address and telephone numbers.
• Date of birth.
• Details of your qualifications, skills, experience and employment history.
• Any details you enter in to any application form (either paper or online).
• Any answers to questions that correspond with your recruitment preferences.
• Any supporting information that you provide to expand your candidate profile.
• Information about your current level of remuneration, including benefit entitlements.
• CCTV footage and other information obtained through electronic means such as fob records; car registration details via our Automatic Number Plate Recognition system.

We may also collect, store and use the following "special categories" of more sensitive personal information:

• Information about your nationality.

• Information about your health.
• Information about criminal convictions and offences.

How we collect and store your personal information

We collect personal information through the application and recruitment process, either directly from candidates or from an employment agency. We collect this information in a variety of ways e.g. via our online recruitment system, in application forms, CVs, covering letters, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

We may sometimes collect additional information from third parties including former employers and the Disclosure and Barring Service. We will seek information from third parties only once a job offer has been made to you and will inform you that we are doing so.

Data will be stored in a range of different places including in our online recruitment software, in recruitment records, in our HR systems and on other IT systems including email.

We use a “Data Processor” in order to collect, store and securely transfer your data via our online recruitment software; the Data Processor is Talos 360 Basecamp, 4 Webster Court, Carina Park, Warrington, WA5 8WD. The Data Protection Officer for Talos 360 can be contacted at: info@talos360.co.uk. By using our online recruitment software you are agreeing to your data being held, stored and processed according to this Privacy Notice.  

How we use your personal information

We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from candidates allows us to manage the recruitment process, assess and confirm suitability for employment and make decisions about job offers. We may also use your data to contact you about other similar job opportunities within 12 months of your original application (unless you have requested for this not to happen) and may also statistically analyse your data. Where we rely on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of candidates and have concluded that they are not.

We also need to process data to ensure that we are complying with our legal obligations, e.g. checking eligibility to work in the UK before employment starts, and we may need to use the Home Office Employer Checking Service. If this is the case, we will ask for your consent. Furthermore, we need to process data to take steps at your request prior to entering into a contract with you. We also need to process your data to enter into a contract with you.

We have a legitimate interest to protect our property, customers and people and we therefore operate a CCTV system, and an Automatic Number Plate Recognition system, in our Plumpton Park car park which records images for security.

We may also need to process data from candidates to respond to and defend against legal claims.

How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place appropriate safeguards which we are required by law to maintain when processing such data.

We may process special categories of personal information where we need to carry out our legal obligations or exercise rights in connection with employment. Specifically, we will use your sensitive personal information in the following ways:

• We will use information about your health to make reasonable adjustments during the recruitment process, if required.
• We will use information about your health via a Health Questionnaire, which we will ask you to complete after we have made a job offer, so that our Occupational Health team can assess your fitness for the role you have been offered. During the processing of our Health Questionnaire, if you have a medical condition that requires adjustments in the workplace or if it is important for your Line Manager to be aware to support you in your role, or there is a Health and Safety reason for doing this, then the Occupational Health Clinicians will advise the Health and Safety team who will communicate this to your Line Manager and HR. If you are an agency worker this will be via the recruitment agency. Additionally, if, as a consequence of your medical condition, you are deemed to have a protected characteristic under the Equality Act 2010, your Line Manager and HR will be advised of this fact. For agency workers this will be communicated to the Line Manager via the Recruitment Agency.
• We will use information about your nationality to check that you are legally entitled to work in the UK.

In order to analyse our recruitment processes and support our Equity, Diversity and Inclusion aims, we request Equal Opportunities data about your ethnic origin, nationality, gender, age, health, sexual orientation and religion or belief as part of our online application process. Any information you disclose is anonymised and used for equal opportunities monitoring purposes only and providing it is entirely voluntary. It will not be accessible by recruiting managers (or any other employees at Bettys & Taylors Group) and will not play any part in our recruitment and selection processes. In the event you are offered a role, if you have any information you would like to share, e.g. you may wish to have a conversation with your line manager about a reasonable adjustment for a disability, this will need to be disclosed separately.

Information about criminal convictions

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process in the following ways:

• To ensure we comply with legal requirements in relation to Disclosure and Barring Service checks.
• To ensure suitability for certain roles where certain criminal convictions may pose a serious risk to our business.
• To ensure fitness for driving duties, either on company business or as part of your role.

We are allowed to use your personal information in this way to carry out our obligations and exercise specific rights in relation to employment and for our legitimate interests. We have in place appropriate safeguards which we are required by law to maintain when processing such data.

Automated decision-making

Bettys & Taylors Group Ltd does not currently have a Sponsorship Licence so we are unable to recruit anyone who does not have eligibility to work in the UK. Our online recruitment system therefore uses automated decision-making to sift out candidates who do not have the right to work in the UK. If you answer ‘No’ to the relevant question in your online application submission, your application will be sifted out and you will not be able to progress any further in the recruitment process. Our online recruitment system may also sift out your application if you confirm that you are unable to work the specified working hours/pattern for the role.

If you would like to obtain human intervention in this automated decision-making process, express your point of view and/or contest the decision, please contact the Company Secretariat department on 01423 814000.

Who has access to your personal data?

The data that you submit to our online recruitment site may be:

• made available to the Data Controller;
• made available to the Data Processor;
• used to communicate with you about your application;
• used to communicate with you in relation to a recruitment process;
• used to supply you with relevant (optional) job alerts;
• added to a searchable candidate database;
• analysed for our internal statistics to improve processes;

Sometimes information may be processed on behalf of our Data Processor (360 Resourcing) by relevant third parties; this includes but is not limited to: video interviewing companies, Docu-sign (an online contract signing software provider) and Trust ID (a right to work checks service provider).

Your information will be also shared internally for the purposes of the recruitment process. This may include members of the HR team, Team Leaders/Managers involved in the recruitment process, Occupational Health, and IT if access to the data is necessary for the performance of their roles.

We may share your personal information with other third parties where required by law, or where we have another legitimate interest in doing so (for example we may need to provide information to our insurers if you are involved in, or witness, an accident during a visit to one of our sites for interview). We may also need to share your personal information with a regulator or to otherwise comply with the law. We require third parties to respect the security of your data and to treat it in accordance with the law.

We will not share your data with third parties, apart from in the circumstances explicitly stated above, unless your application for employment is successful and we make you an offer of employment.

We do not envisage that we will transfer the personal data we collect about you outside the EU, however we will update this Privacy Notice if this position changes.

How do we protect your personal data?

We take the security of your data seriously. We have 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 people in the proper performance of their duties. The technology that we use for our online recruitment system has been designed with your security in mind. Our Data Processor’s servers are based in the UK and they deploy both technological and operational security measures along with internal policies specifically implemented to protect your data.

How long do we keep your personal data?

If your application is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process. During this period, we may contact you regarding other employment opportunities we think you may be suitable for unless you have requested for this not to happen). After 12 months your data is deleted or destroyed.

If your candidate account in our online recruitment system is inactive for 12 months, it will be deactivated. You can also request to withdraw your details at any time and thereafter your data will be fully anonymised for further protection.

If your application for employment is successful, personal data gathered during the application and recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will subsequently be held will be provided to you in our Privacy Notice for Employees. Your candidate data will remain on our online recruitment system for 12 months after your online application was submitted.

Your rights

Under certain circumstances, by law, you have the right to:

• access and obtain a copy of your personal data on request;
• require us to change incorrect or incomplete data;
• require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing;
• ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation's legitimate grounds for processing data;
• request the transfer of your personal data to another party.

If you want to exercise any of these rights, please contact the Company Secretariat department in writing at the address below.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

Data protection enquiries

If you have any questions about this Privacy Notice or how we handle your personal information, please contact the Company Secretariat department in writing at Bettys & Taylors Group Ltd, Pagoda House, Plumpton Park, Harrogate, HG2 7LD.

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.

Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time.