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Recruitment Privacy Policy

Wilton Park Recruitment Privacy Notice

This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).

Your data

The data

We will process the following personal data:

When you make an application we may ask for:

  • full contact details, including address, and mobile phone number
  • eligibility – nationality and immigration status
  • employment history
  • qualifications, licences and professional memberships
  • diversity and inclusion information
  • CV and personal statement
  • Disability Confident Scheme and reasonable adjustment requirements

When you are invited to an interview we may ask you to provide:

  • evidence of your identity and right to work in the UK – such as your passport, utility bills or other documentation

When you undergo pre-employment checks we may ask for:

  • Nationality and right to work information
  • contact details for your referees
  • National Insurance number
  • date of birth
  • public sector pension history
  • health declaration
  • evidence of time spent outside of the UK
  • details of any self-employment
  • evidence of current Disclosure and Barring Service (DBS) certificate
  • bankruptcy details
  • addresses for the last 10 years
  • passport details
  • driving licence details
  • previous names you have been known by
  • workplace discipline information
  • criminal history

If you are already working for the Civil Service and moving to another government department, we may also ask for:

  • two most recent consecutive payslips
  • current National Security Vetting clearance
  • current employee number

When you contact us with feedback or an enquiry we will process:

  • your email address
  • the details of your request

Purpose

The purposes for which we are processing your personal data are:

  • to manage recruitment for Wilton Park. This includes sift tests, interview scheduling, and pre-employment checking service
  • to assess your suitability for a role
  • to send your contract of employment to your email address
  • to monitor the effectiveness of recruitment processes – this could include statistical analysis of system usage, or research into the experience of applicants and other system users, or analysing referral sources to see which provide the most diverse applicants
  • to undertake pre-employment checking and onboarding activity before you start in a role in the Civil Service (including health, pension questionnaire, character declaration)
  • to complete a ‘fit-for-work’ disclaimer in regards to the COVID-19 pandemic
  • to comply with the Baseline Personnel Security Standard (BPSS) which consists of:
  • verification of identity
  • verification of nationality and immigration status – including entitlement to undertake the work in question
  • verification of employment history – through cross-referencing information against the HMRC PAYE system or through references
  • verification of criminal record (unspent convictions) – for HMRC vacancies this check will also include spent convictions
  • additional verification – only applies where additional verification or assurance is required

Legal basis of processing

The legal basis for processing your personal data is:

  • Contractual: it is necessary for the performance of a contract to which you are a party – an employment contract. This relates to information that we need to recruit and employ you.
  • Contractual: it is necessary in order to take steps at your request prior to entering into a contract for employment. This relates to information that we collect as part of the application and selection process.
  • Legal obligation: it is necessary to comply with a legal obligation placed on us as the data controller – we are required to report on equality of opportunity; and onboarding processes have specific requirements
  • Public task: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller. In this case, Civil Service Jobs facilitates recruitment of high-quality candidates to roles across government departments, agencies and other public bodies. It provides recruitment tools and processes that support Civil Service recruitment strategy, and we also monitor the effectiveness of recruitment processes.

Sensitive personal data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

The legal basis for processing your sensitive personal data is:

  • it is necessary for the purposes of performing or exercising our obligations or rights as the controller, or your obligations or rights as the data subject, under employment law, social security law or the law relating to social protection. External recruitment is required to follow the Civil Service Commission Recruitment Principles. Personal data is processed to ensure that these requirements are met. We are required under the Equality Act 2010 to make appropriate reasonable adjustments for candidates with a disability.
  • processing is of a specific category of personal data and it is necessary for the purposes of identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people specified (in paragraph 8(2) of Part 2 of Schedule 1 to the Data Protection Act 2018) in relation to that category with a view to enabling such equality to be promoted or maintained; and it is not carried out for the purposes of measures or decisions with respect to a particular data subject; and you have not declined consent; and you have not given notice that you do not wish your data to be processed for these purposes; and the processing is not likely to cause substantial damage or substantial distress to an individual. Diversity and inclusion data is used anonymously: ethnicity, religion and sexual orientation.
  • it is necessary for archiving purposes, scientific or historical research purposes or statistical purposes, and it is in the public interest. Analysis of applications and recruitment outcomes (including online tests), impact on protected groups, timescales for recruitment, and other research may be carried out.

The processing by us of personal data relating to criminal convictions and offences or related security measures is not carried out under official authority, but is authorised because it meets the following condition:

  • it is necessary for reasons of substantial public interest. This is ensuring that individuals with access to official information and assets will meet the required standards of propriety.

Recipients

Once you have made an application, your information may be shared with:

  • approved staff managing vacancies (including recruiters and interview panel members)
  • the recruiting departments or profession
  • Providers of individual leadership assessments, psychometric tests and staff engagement exercises
  • Civil Service Commission, Advisory Committee on Business Appointments, Office of the Commissioner for Public Appointments – to ensure that recruitment processes are correctly followed

If you meet the required standard but the recruiting department is unable to offer you the job, you may be given the option of being added to a reserve list.

If you undergo pre-employment checks prior to appointment, your data may be shared with:

  • Customer relationship management system
  • Disclosure and Barring Service
  • occupational health providers
  • Civil Service Pensions
  • the recruiting department
  • the UK Security Vetting team, as well as the Security Cluster department for the relevant employer (which will be either HMRC, DWP, Home Office, MoD, or the FCDO)

If you request support with your application or for a technical issue:

  • approved staff from Cabinet Office
  • approved staff from our technical supplier
  • customer relationship management system
  • project management tools
  • technical suppliers of online tests

As your personal data will be stored on our IT infrastructure it will also be shared with our data processors who provide email and document management and storage services to us.

Once the retention period has elapsed, we will ensure that any disclosure information is immediately destroyed by secure means. While awaiting destruction, disclosure information will not be kept in any unsecured receptacle. We will not keep any photocopy or other image of the disclosure or any copy or representation of the contents of a disclosure or any other relevant non-conviction information supplied by police. However, despite the above, we may keep a record of the date of issue of a disclosure, the name of the subject, the type of disclosure requested, the position for which the disclosure was requested and the details of the recruitment decision.

Retention

Your personal data will be kept by us for the following durations:

Application records and associated files (including CVs, letters, emails, criminal history certificates, comment and feedback) will be deleted 2 years after the vacancy is archived. A vacancy becomes archived when there are no active applications and either:

  • the vacancy is manually archived by a recruiter; or
  • the vacancy is automatically archived 1 year after the advertised closing date.

Your rights

You have the right to request information about how your personal data is processed, and to request a copy of that personal data.

You have the right to request a copy of any personal data you have provided, and for this to be provided in a structured, commonly used and machine-readable format.

You have the right to request that any inaccuracies in your personal data are rectified without delay.

  • you can also edit contact details on submitted applications
  • to request corrections to an application you have submitted, email the contact listed on the advert for that vacancy – however only minor updates are usually considered

You have the right to request that any incomplete personal data are completed, including by means of a supplementary statement.

  • in most cases, you will be unable to submit an application if mandatory information is missing
  • please check your application carefully before submitting it, as your application will be assessed on the information you provide at that point

You have the right to request that your personal data is erased if there is no longer a justification for it to be processed.

You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted.

  • if your data is restricted from processing, you cannot be considered for a job
  • if your request relates to an application, email the contact listed on the job advert

You have the right to object to the processing of your personal data where it is processed for direct marketing purposes.

  • your data is not processed for direct marketing purposes

You have the right to object to the processing of your personal data.

  • you can object to processing, although you will then be unable to be considered for a job

You have the right, in relation to automatic profiling, to obtain human intervention in the outcome, to express your point of view, and to contest the decision reached by automatic profiling.

  • you can email the contact listed on the advert for the job you have applied for

International transfers

As your personal data is stored on our IT infrastructure, and shared with our data processors who provide email, and document management and storage services, it may be transferred and stored securely outside the European Economic Area. Where that is the case it will be subject to equivalent legal protection through the use of Model Contract Clauses.

Complaints

If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113
casework@ico.org.uk

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

Contact details

Wilton Park is the data controller for your personal data within your submitted applications.

You can contact Human Resources by email: humanresources@wiltonpark.org.uk

The contact details for Wilton Park’s Data Protection Officer (DPO) are:

Ian Atkinson
Data Protection and Compliance Manager
Wilton Park

Wiston House

Steyning

West Sussex

BN44 3DZ

DataProtectionOfficer@wiltonpark.org.uk

Updates to this notice

If this privacy notice changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures you are always aware of what information we collect, how we use it, and under what circumstances we will share it with other parties.

Last updated: 6 October 2021Top of Form

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