Recruitment Privacy Information Notice (RPIN)

RECRUITMENT – Privacy Information Notice

You have indicated that you wish to apply for employment (Application) within the HIGHVERN group of companies (HIGHVERN). HIGHVERN are committed to protecting the privacy and security of your personal information. This Privacy Statement describes how we collect and use personal information about you during the recruitment process, how we protect this information and the choices you can make about how we use this information in accordance with the GDPR and equivalent data protection legislation in your jurisdiction. It applies to individuals making applications for employment directly with us or those on behalf of whom an application is made, e.g., through recruitment agencies.

The purpose of this notice is to inform you of the types of Personal Data that HIGHVERN will obtain from you during the course of considering your application, what we will do with that Personal Data, the organisations with whom we might share that Personal Data and your main rights in respect of that Personal Data. You are under no statutory or contractual obligation to provide personal data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application.

In order to consider your Application HIGHVERN requires Personal Data in relation to you. This Personal Data is largely initially collected at or around the time of your application and will be maintained throughout the period of the Application. Should the Application be successful and lead to you accepting an offer of employment with HIGHVERN then that Personal Data (as well as further Personal Data that we will need to administer your employment with us) will be kept by HIGHVERN as part of your personnel record. Should your application prove unsuccessful then the Personal Data collected will be destroyed within six months of the end of the Application process unless both you and we agree otherwise. If you choose to join our talent pool, we will retain your personal data for as long as you are a member of it.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

The Personal Data which HIGHVERN will collect and process for the purposes of your Application may include some or all of the following:

•Basic details (name, address, email, telephone number, right to work status).
•CV, experience, education, academic and professional qualifications.
•Photographs and documents to verify your identity.
•Recruitment platform login information.
•Information provided as part of interviews and assessments (including reasonable adjustments information).
•Social mobility data (where you choose to provide this); and
•Diversity and equal opportunities data (where you choose to provide this).
•Your residential addresses (current and historical)
•Your date of birth
•Your gender
•Your town of birth
•Your nationality
•Your country of birth
•Your telephone numbers
•Your e-mail addresses
•Your passport/identification card numbers
•Your image
•Your mother’s maiden name
•Your Social Security Number or equivalent
•Your tax ID number
•Details in relation to your employer and employment history
•Details in relation to your family and next of kin
•Data recorded by CCTV cameras located in the lobby of the second floor of HIGHVERN’s building, in the reception on the third floor of HIGHVERN’s building and on in the communications room

We also create personal data in the course of our recruitment activities with you, including:

• Assessment results and feedback from online and face-to-face assessments / tests; and
• Employment offer details.

We may collect this information in a variety of ways.
• Directly from you: where you have directly applied for a position with us.
• From recruitment agencies, platforms and websites: where a recruitment agency with your information puts you forward for a role.
• From publicly available sources: where you are a member of social media boards and/or job websites, including professional networking sites e.g. LinkedIn.
• From information from social media sites: where you are a member of the site to gather information about your engagement with our recruitment campaigns (Please see our Cookies Statement for further information).

If your application with us is successful, we will collect:

• Additional information as part of our pre-employment screening process such as proof of right to work, background checks, qualifications and professional status, employment history and referencing;
• Information about you and your immediate family’s financial relationships for independence regulatory compliance purposes; and
• Bank account details, national insurance number (or similar) and tax status

Purposes for which Personal Data is collected

The purpose for which we will collect and process your Personal Data is to facilitate your application.

We will only use your personal information when the law allows us to. We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. We will use your data for the following purposes:

• To process and manage applications, and evaluate you for open positions that match your interests and experience.
• To screen and select talent by evaluating your suitability for employment, including through face-to-face interviews, video interviews, online and video assessments, and conducting appropriate background checks.
• To hire and onboard talent by making offers of employment and carrying out pre-employment screening checks.
• To attract talent and market opportunities by arranging, hosting and participating in events, marketing and advertising our job opportunities, and using recruiters to help find talent for us.
• To identify and source talent including by searching our existing talent pool and publicly available sources (such as social media and job websites of which you are a member).
• To manage your candidate profile, send you email notifications and other announcements, request additional information or otherwise contact you about your application.
• To conduct statistical analyses and create internal reports, for example regarding usage of our careers websites, demographic analysis of candidates, our recruitment activities, and analysis of candidate sourcing channels.
• To administer and manage our careers websites, and other recruitment tools and solutions.
• To communicate with you about other career opportunities.
• To make reasonable adjustments to our selection processes.
• To send you, welcome information or items once an offer is made by email or post.
• Any other purposes stated when you provide your personal data information to us.

In some cases, we need to process your personal information to ensure that we are complying with our legal obligations. For example, it is mandatory to check a successful applicant’s eligibility to work in the UK before employment starts.

If your application is unsuccessful, we will keep your personal information on file in case there are future employment opportunities for which you may be suited.

We carry out criminal records checks for the following purposes:

• To comply with our legal obligations to ensure an individual is eligible to work in your jurisdiction and to report relevant information to the relevant government departments.
• For our legitimate interest or that of a third party to carry out pre-employment screening including a full background and criminal records check, depending on the role: (i) to establish whether an applicant has committed an unlawful act or been involved in dishonesty, malpractice or other seriously improper conduct; or (ii) to comply with government and public sector clearance requirements.
• For reasons of substantial public interest, including complying with regulatory requirements relating to unlawful acts and dishonesty.

AUTOMATED DECISION MAKING

Automated decision making takes place when an electronic system uses personal information to make a decision without human intervention. We do not use automated decision making.

Sharing Personal Data

We only share your Personal Data with other organisations for one of two reasons – (i) because we are legally obliged to or (ii) because doing so allows us to evaluate your application for employment with HIGHVERN. We do not share your Personal Data with anybody else for marketing purposes (either ours or those of the relevant third party).

Organisations who we might be legally obliged to share your Personal Data in certain circumstances are essentially governmental authorities – e.g., regulators. Whilst sharing information with these bodies is compulsory, data protection rules also apply to them and your Personal Data should be as secure with them as it is with us.

The other organisations with whom we may share your Personal Data in order to evaluate your application fall into the following broad categories:

(i) referees (e.g., previous employers);
(ii) governmental and other agencies that provide the facility to conduct criminal or similar record searches;
(iii) credit rating agencies; and
(iv) legal or other professional advisors where necessary.

In each case HIGHVERN will ensure that any such organisation is bound by similar rules relating to data security and, in the case of organisations outside of the European Economic Area (EEA), have entered into specific contractual terms with us to ensure that they treat your Personal Data in a way equivalent to that in which they would be required to do so were they established within the EEA.

Your Rights in respect of Personal Data

Data protection legislation confers a number of rights on you in relation to your Personal Data which HIGHVERN collects, processes and shares in the manner described above. Whilst the specific rights may vary from jurisdiction to jurisdiction (depending on the HIGHVERN company you are applying to work for) these normally include:

(i) a right to require us to tell you what Personal Data we hold in respect of you and what we’re doing with it;

(ii) a right to ask to have that Personal Data corrected if it is inaccurate; and

(iii) a right to ask us to erase your Personal Data from its records if there is no longer a legitimate reason for us to hold that Personal Data.

If you become aware of the fact that the personal data we hold in respect of you becomes inaccurate during the course of your Application you should inform HIGHVERN of this immediately.

Finally, if at any stage you become dissatisfied with the manner in which HIGHVERN collects, holds or processes your Personal Data you have the right to complain to the relevant data protection authority or equivalent regulator in the jurisdiction in which you are applying to for employment.

If you have any questions or concerns in relation to the contents of this notice please approach either your HR contact or, alternatively, HIGHVERN’s Data Protection Officer by emailing dpo@highvern.com