Recruitment and Candidate Privacy Notice
Personal Data We Collect During Recruitment
Ant Marketing Limited is a “controller” in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. When you apply for a role us, we may collect, use, store and process personal information relating to you as part of our recruitment processes.
The purpose of this notice is to make you aware of how and why your personal data will be used, namely for the purposes of the recruitment process, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR).
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 personal data we will collect, store, and use in connection with your application for work with us may include:
- Identity data, including your name, date of birth and right to work information.
- Contact data, including your address, email address and telephone number.
- Recruitment data, including your CV, employment history, qualifications, skills, references, interview notes and assessment results.
- Right to work documentation and proof of identity.
- Background screening information where required for the role, including DBS and BPSS checks where applicable.
- Any other information you choose to provide during the recruitment process.
How We Collect Your Information
We may collect personal data directly from you when you:
- Submit an application through our website, job boards or recruitment agencies.
- Attend interviews or assessments.
- Communicate with us during the recruitment process.
We may also receive information from recruitment agencies, referees, background screening providers, the Disclosure and Barring Service in respect of criminal convictions, and publicly available professional networking sites where permitted by law.
This may involve us collecting, storing and using the following types of more sensitive personal information:
Information about your religious or philosophical beliefs.
Information about criminal convictions and offences.
How We Use Candidate Information
We process candidate personal data for the purposes of:
- Assessing your suitability for current and future employment opportunities by assessing your skills, qualifications, and suitability for the role.
- Managing and administering the recruitment process.
- Verifying qualifications, experience and eligibility to work in the United Kingdom.
- Conducting pre-employment screening and background checks where appropriate.
- Communicating with you regarding your application and recruitment status/process.
- Complying with legal and regulatory obligations.
It is in our legitimate interests to decide whether to appoint you to a role since it would be beneficial to our business to appoint someone to that role.
We may sometimes use your personal data because we have a recognised legitimate interest. Where we rely on a recognised legitimate interest, we will ensure the use is strictly necessary and only use or share the minimum data required.
We also need to process your personal information to decide whether to enter into a contract with you.
Lawful Basis for Processing
We process candidate personal data on the basis of:
- Taking steps at your request prior to entering into an employment contract.
- Our legitimate interests in recruiting and selecting suitable candidates.
- Compliance with legal obligations, including employment, immigration and safeguarding requirements.
- Where required, your consent for specific processing activities.
Before we use your personal data for any new purpose, we will ensure the processing is fair and lawful. In particular, we will confirm that an appropriate lawful basis applies to the new purpose and (where relevant) that any additional requirements for special category data or criminal offence data are met. We will carefully consider whether any new use is compatible with the original purpose for which your data was collected.
We will not use your personal data in ways that are unexpected, unfair, or that could have an unjustified negative impact on you.
In certain circumstances, the law treats further processing as compatible without requiring a full compatibility assessment, for example, where processing is carried out for archiving in the public interest, scientific or historical research, or statistical purposes, provided appropriate safeguards are in place.
Where we do intend to use your data for a new purpose, we will inform you and provide any relevant information before doing so. In some cases, you will have the right to object to that use, and we will make you aware of this right whenever it applies.
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), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
Special Category Data and Criminal Conviction Data
Where necessary and permitted by law, we may process special category data and criminal conviction data for recruitment purposes, including DBS or BPSS screening. Such information will only be processed where an appropriate legal basis and condition under UK data protection law applies, for example:
- We use information about disability to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
- We use information about racial or ethnic origin, religious or philosophical beliefs, disability or sexual orientation to ensure meaningful equal opportunity monitoring and reporting.
We 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 the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:
- The role of certain Customer Services and Telesales roles require a high degree of trust and integrity since it involves dealing with vulnerable customers and sensitive information. As a result we would ask for your consent for us to process a basic or enhanced disclosure of your criminal records history.
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
Automated decision-making is the process of making decisions by automated means, with or without any human involvement
We do not make decisions about you based solely on automated processing that would have legal, or similarly significant, effects for you. We will notify you if this position changes.
Cookies and Similar Technologies
Our website uses cookies and similar technologies (cookies). Some cookies are essential for functionality and security. We also use cookies (including those set by trusted third parties) to help us understand how candidates use our recruitment pages, improve the website, and measure the effectiveness of our recruitment activity. For analytics and optimisation cookies, we provide clear information and an easy way to opt out through our cookie settings. Some cookies, particularly those set by third parties for advertising or tracking purposes, require your consent before we place them on your device. For more information about what cookies are, how we use them, including which third parties may set cookies and their purposes, please contact our HR Department. You can change your cookie preferences at any time through our cookie settings.
Sharing Your Information
Your personal data may be shared with the following third parties for the purposes of processing your application:
- Recruitment agencies acting on our behalf.
- Background screening and verification providers.
- Professional advisers, regulators or legal authorities where required.
- Group companies within Ant Marketing where relevant to the recruitment process.
We require all third parties to respect the security of your personal data and to process it in accordance with applicable data protection laws. We 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 our instructions.
We will not transfer your personal information outside the UK.
Data Security
We 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. Details of these measures may be obtained from our HR Department.
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.
Retention of Candidate Data
If your application is unsuccessful, we will normally retain your personal data for up to 12 months following the completion of the recruitment process, unless a longer retention period is required by law or you consent to a longer retention period for future opportunities. We retain your personal information for that period 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 process 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 are successful, your recruitment information will become part of your employee record and will be retained in accordance with our employee privacy policies and retention schedules.
Your Rights
As a candidate, you have the legal right, under certain circumstances, to:
- Request access to your personal data. We will conduct a reasonable and proportionate search for your personal information.
- Request correction of inaccurate information.
- Request erasure of your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
- Object to or restrict certain processing activities.
- Request the transfer of your personal information to another party.
- Lodge a complaint with the Information Commissioner’s Office (ICO).
For any questions regarding the processing of candidate data or to exercise your rights, please contact our Data Privacy Manager at [email protected].
You have the right to complain to us if you consider that there has been an infringement of your rights in relation to your personal data.
You can submit a complaint using the following channels:
- Email: [email protected]
- Post: Ant Marketing Ltd, 14 Church Street, The Chambers, Sheffield, S1 2GN
When we receive a data protection complaint, we will:
- Acknowledge receipt no later than 30 days from receiving it.
- Take appropriate steps to respond without undue delay, which may include making enquiries into the subject matter of the complaint and, where appropriate, keeping you informed about the progress of our handling of the complaint.
- Inform you of the outcome without undue delay.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), who is responsible for data protection issues in the UK and whose contact details are available from our Data Privacy Manager.
