GDPR Privacy Notice – Recruitment

Privacy notice (recruitment)

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This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the application process. We are required to notify you of this information, under data protection legislation.

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Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notices we may provide to you from time to time when we collect or process personal information about you.

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Who collects the information

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Leonard Curtis Business Solutions Group (‘Group’) is a ‘data controller’ and gathers and uses certain information about you. This information is also used by our affiliated entities and group companies, namelyLeonard Curtis (UK) Limited, Leonard Curtis (Funding) Limited, LC Risk Management Limited, LC Debt Solutions Limited, Leonard Curtis Legal Limited, Leonard Curtis C.I. Limited, Leonard Curtis (Offshore) Limited, Leonard Curtis Jersey Limited and Reach Commercial Finance Limited (our ‘group companies’) and so, in this notice, references to ‘we’ or ‘us’ mean the Group and our group companies.

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Data protection principles

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We will comply with the data protection principles when gathering and using personal information, as set out in our data protection policy.

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About the information we collect and hold

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The table set out in Part A of the Schedule below summarises the information we collect and hold up to and including the shortlisting stage of the recruitment process, how and why we do so, how we use it and with whom it may be shared.

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The table in Part B of the Schedule below summarises the additional information we collect before making a final decision to recruit, i.e. before making an offer of employment unconditional, how and why we do so, how we use it and with whom it may be shared.

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We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

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Where information may be held

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Information may be held at our offices and those of our group companies, and third party agencies, service providers, representatives and agents as described above.

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How long we keep your information

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We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.

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We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised, and the longer period for which they will be kept.

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If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment. For further information, see our data protection privacy notice (employment).

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Further details on our approach to information retention and destruction are available in our document management policy which is available from our HR department.

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Your rights to correct and access your information and to ask for it to be erased

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Please contact our Privacy Manager, who can be contacted on privacy@leonardcurtis.co.uk or by mail to Group Privacy Manager, 1A Elms Square, Bury New Road, Whitefield M45 7TA, if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice.

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You also have the right to ask our Privacy Manager for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances and our Privacy Manager will provide you with further information about the right to be forgotten, if you ask for it.

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Keeping your personal information secure

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We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

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How to complain

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We hope that Privacy Manager can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

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SCHEDULE – About the information we collect and hold

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Part A

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Up to and including the shortlisting stage

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The information we collect
How we collect the information
Why we collect the information
How we use and may share the information
Your name and contact details (i.e. address, home and mobile phone numbers, email address)
From you / a Recruitment Agency
Legitimate interest: to carry out a fair recruitment process

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Legitimate interest: to progress your application, arrange interviews and inform you of the outcome at all stages
To enable HR or the manager of the relevant department to contact you to progress your application, arrange interviews and inform you of the outcome

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To inform the relevant manager or department of your application
Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests
From you, in the completed application form and / or interview notes (if relevant)
Legitimate interest: to carry out a fair recruitment process

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Legitimate interest: to make an informed decision to shortlist for interview and (if relevant) to recruit
To make an informed recruitment decision

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Your name, contact details and details of your qualifications, experience, employment history and interests
From you, in the completed application form and / or interview notes (if relevant)
Legitimate interest: to carry out a fair recruitment process

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Legitimate interest: if you are unsuccessful in your application, your details may be passed on to an associated company to see if they have any suitable vacancies
To see whether an associated company has any suitable vacancies
Information regarding your criminal record where appropriate
From you, in your completed application form
To comply with our legal obligations

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For reasons of substantial public interest (preventing or detecting unlawful acts, suspicion of money laundering in the regulated sector and protecting the public against dishonesty)
To make an informed recruitment decision

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To carry out statutory checks

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Information shared with DBS and other regulatory authorities as required

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For further information, see * below
Details of your referees
From your completed application form / CV or an Agency
Legitimate interest: to carry out a fair recruitment process

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In the regulated sector, to comply with our legal obligations to obtain regulatory references
To carry out a fair recruitment process

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To comply with legal/regulatory obligations

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Information shared with relevant managers, HR personnel and the referee
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Part B
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Before making a final decision to recruit

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The information we collect
How we collect the information
Why we collect the information
How we use and may share the information
Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers ☐
From your referees (details of whom you will have provided)
Legitimate interest: to make an informed decision to recruit

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To comply with our legal obligations

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Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice
To obtain the relevant reference about you

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To comply with legal/regulatory obligations

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Information shared with relevant managers and HR personnel
Information regarding your academic and professional qualifications ☐
From you, from your education provider, from the relevant professional body
Legitimate interest: to verify the qualifications information provided by you
To make an informed recruitment decision
Information regarding your criminal record, in criminal records certificates (CRCs) and enhanced criminal records certificates (ECRCs) where appropriate ☐
From you and from the Disclosure and Barring Service (DBS)
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To perform the employment contract and to comply with our legal obligations and fulfil our legitimate interest to verify the criminal records information provided by you

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To make an informed recruitment decision

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To carry out statutory checks

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Information shared with DBS and other regulatory authorities as required

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For further information, see * below
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Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information ☐
From you and, where necessary, the Home Office
To enter into/perform the employment contract

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To comply with our legal obligations

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Legitimate interest: to maintain employment records
To carry out right to work checks

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Information may be shared with the Home Office
A copy of your driving licence
From you
To enter into/perform the employment contract

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To comply with our legal obligations

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To comply with the terms of our insurance
To make an informed recruitment decision

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To ensure that you have a clean driving licence

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Information may be shared with our insurer
You are required (by law or in order to enter into your contract of employment) to provide the categories of information marked ‘☐’ above to us to enable us to verify your right to work and suitability for the position.

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Where we share personal information with other parties, such as HR consultants and professional advisers, this will sometimes will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information with our regulators or as required to comply with the law.

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* Further details on how we handle sensitive personal information and information relating to criminal convictions and offences are set out in our Data Protection Policy which is available from the HR department.

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