Tower Hamlets Homes

Job Applicant Privacy Statement

Data controller: Tower Hamlets Homes Limited, Second Floor, City Reach, 5 Greenwich view Place, London E14 9NN

Data protection officer: Chris Smith, Head of Resources

As part of any recruitment process, Tower Hamlets Homes (THH) collects and processes personal data relating to job applicants.  We (THH) are committed to being transparent about how we collect and use that data, as well as to meeting our data protection obligations.  The following statement explains how we intend to use the information you provide in your application, along with your rights, our reasons for requesting it and who will have access to it.

What information do we collect from you?

We collect information that is specifically provided by you as part of an application process. We will collect the following (but not limited to):

• Name, address, email, telephone number;
• CV (if applicable) and/or details of qualifications, skills, employment experience and professional memberships;
• Information about your current level of remuneration, including benefit entitlements;
• Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
• Equal opportunities monitoring information (defined as special categories data) – this information is purely for statistical analysis and monitoring purposes;
• Answers to application questions;
• Information on your that is publically available on your social media profile (i.e. LinkedIn);
• Assessments of your performance in selection exercises;
• Any other information you wish to provide in support of your application.

By agreeing to this privacy statement, you are allowing us to form a contract that will mean we can use your details and information presented so that we can assess your suitability for employment with us and carry out our statistical analysis.

Why do we collect this information and who do we share it with?

Details you provide in this application:

• Will be held on our computer systems and may be downloaded by us;
• Will be used to deal with your application;
• Will be made available to us and our processors;
• Will be used for communication with you regarding the vacancy;
• Will be used to satisfy legal requirements;
• Will be used for statistical analysis;
• Will be held and may be used to contact you about other vacancies.

We process health information during the application process if we need to make reasonable adjustments to the recruitment process for candidates who have a disability.  This is to carry out our obligations and exercise specific rights in relation to employment.

Should you be successful from the application stage, you may be required to carry out a video interview.  We use our third party provider, The Needle to carry this out.  We only send them the minimum amount of data required to perform this action.  To view The Needle’s privacy policy, go to https://theneedleonline.com/about/privacy-data-protection.

Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes and statistical analysis.

If your application is unsuccessful, we will store your application data for 6 months after the vacancy has closed.  During this period, we may consider you for other job opportunities that may arise.  We will ask for your consent before we process your data further for this purpose and you are free to withdraw your consent for this at any time.  At the end of the 6 month period your data will be fully anonymised.

If your application for employment is successful, personal data gathered during the recruitment process may 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 statement.

Where we make you a conditional offer of employment, 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 in order to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with our legal obligations.  For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts.

We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process.  Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job.  We may also need to process data from job applicants to respond to and defend against legal claims.

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 employees or workers and have concluded that they are not.

For some roles, we seek information about criminal convictions and offences.  Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.

Our recruitment process requires that we contact the referees provided by you as part of our checks to ascertain suitability of employment.  The content of the reference will not be shared without the referee's permission.  If you are successful in your application, we will store references given by your referees for a period of 12 months after your commencement of employment.

If a conditional offer of employment is made to you, we will also seek to collect other personal data about you from third parties, such as information from employment background check providers, information relating to your right to work in the UK, information relating to your driving licence, vehicle and vehicle insurance, information relating to your medical health, and information from criminal records checks.  We will provide a further privacy statement containing more information at the time of requesting this information.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise.  This includes members of the HR/People Services 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.

We will share your data with third parties involved in the assessment and selection process for the post for which you have applied, such as companies administering online tests or screening interviews on our behalf.  If your application for employment is successful and we make you an offer of employment, we will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks (such as medical and occupational health providers) and the Disclosure and Barring Service to obtain necessary criminal records checks.

We will not transfer your data outside the European Economic Area.

How does THH protect data?

We take the security of your data seriously.  We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.  All electronic data is stored through IT systems where login ID and password will be required.  Third parties will be reminded of the general data protection regulations when we share reports/data extracted from our systems.  Information security requirements and compliance with the general data protection regulations is accounted for in the procurement of third parties.

Where we engage 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 technical and organisational measures to ensure the security of data.

How can I access the information you hold about me (your rights)?

We are dedicated to providing reasonable access to visitors who wish to review the personal information retained when they apply via our website site and correct any inaccuracies it may contain.  If you choose to register, you may access your profile, correct and update your details, or withdraw your details at any time.  To do this, you can access your personal profile by using the secure login.  In all cases we will treat requests to access information or change information in accordance with applicable legal requirements.

You have the following rights in relation to the way in which we deal with your personal data:

• The right of erasure or to be forgotten;
• The right to rectification if information is inaccurate or out of date;
• The right of data portability (to obtain and reuse your personal data);
• The right to object to networx and the controller and processors regarding handling of your personal data;
• The right to withdraw your consent with regards to the handling of your personal data;
• You have the right to ask for a copy of the information we hold about you (Subject Access Request - S.A.R.);
• You have the right to lodge a complaint with a supervisory authority - the Information Commissioner.

Within your candidate account, you can also use the Download Data feature to generate an XML file of the current data we hold on you that you have provided and/or have access to within the account.

You can make a Subject Access Request by completing the form here.  If you would like to exercise any of the other rights above, please contact the Head of People Services via hr@thh.org.uk.

Where you exercise your right to object or withdraw your consent we may process your personal data without your knowledge or consent where we are permitted or required by law or regulatory requirements to do so.  In such a case, we will not process more personal data than is required under the circumstances.

If you are not satisfied by our actions, you can seek recourse through our internal complaints procedure.  If you remain dissatisfied, you have the right to refer the matter to the Information Commissioner (www.ico.org.uk) or seek recourse through the courts.

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.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.

Changes to our Privacy Statement

We reserve the right to modify or amend this privacy statement at any time and for any reason, providing it maintains compliance with the General Data Protection Regulation (EU) 2016/679).