Job Applicant Privacy Notice (compliant with GDPR)
As part of any recruitment process, Digraph Transport Supplies Ltd collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information do we collect?
Digraph Transport Supplies Ltd collects a range of “personal data” from you which means any information about an individual from which that person can be identified. It does not include data where the identity of the person concerned has been removed (which is called “Anonymised Data”).
We may collect, use, store and transfer different kinds of personal data about you. This can be broken down into the following categories:
Identity Data includes your name, username or similar identifier, marital status, title, date of birth, personal financial details, and gender (this will primarily be text based, but could also include audio, photos, videos and other forms of media)
Employment and Qualification Data includes details of your employment history, details of your qualifications and the results of tests and interviews you complete during the recruitment process
Contact Data includes your address, email address and telephone numbers
Technical Data includes the internet protocol (IP) address of your device, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website
Profile Data includes your username and password, preferences, feedback and survey responses
Usage Data includes information about how you use our Website
We also collect, use and share “Aggregated Data” for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not reveal your identity. For example, we may aggregate our users’ Usage Data to calculate the percentage of those users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
Special Category Data: We may also collect, store and use the following types of more sensitive personal information:
Information about your race and ethnicity
Information about your health, including any medical condition
Where we are legally allowed to do so, information about criminal convictions and offences
How does Digraph Transport Supplies Ltd collect personal data?
We use different methods to collect data from and about you including:
Direct interactions. You may give us personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes:
Information that you provide to us in a curriculum vitae, covering letter or similar document
Information that you provide by filling in forms on our Website
Information that you provide to us during an in-person, telephone, video or internet interview (interviews may be recorded for training and quality purposes)
Assessment results: some of our recruitment processes may include one or more assessments, the results of which will be collected and used to assess your application
Troubleshooting details: information that you provide when you report a problem with our Website or processes
Contact details: information that you provide when corresponding with us
Third-parties or publicly available sources. We may receive data from various third-parties and public sources such as:
Recruitment Agencies
Someone you know referring you for a role
Background Check Providers
The Disclosure and Barring Service and Disclosure Scotland
Your named referees
Automated technologies or interactions. We may also collect and process the following data automatically when you use our Website:
The internet protocol (IP) address of your device, your login information, details of the type of device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of your device's wireless network interface, or the mobile phone number used by your device), mobile network information, your browser type and version, your time zone setting, browser plug-in types and versions, operating system and platform
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), page response times, download errors and bugs, the length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the Website and any phone number used to call us
Information stored on your device which you consent to share with us (such as contact information, friend lists, login information, photos, videos or other digital content)
Any details of your current location which you consent to share with us
Information provided to us by third-parties (including, for example, business partners, sub-contractors in technical, analytics providers, search information providers and credit reference agencies)
How does Digraph Transport Supplies Ltd use personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where:
We need to perform this contract
It is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests
We need to comply with a legal or regulatory obligation
You have specifically consented to us using your personal data in a particular way
Set out below is a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Please note that we may:
Process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data
Combine information from other sources with information you give to us and that which we collect about you
Use this combined information for the purposes set out below
Activity
1. Managing the recruitment process: This may include:
a) Processing your information to decide whether you meet the basic requirements to be shortlisted for a role
b) Processing your information to determine whether you have a legal right to work for us
c) Circulating and subsequently processing online assessments (which may include personality tests)
d) If you pass our initial assessment, inviting you for an interview (which may be conducted in person or by phone, video or over the internet)
e) Assessing your information and the results of any interview (and comparing it to other applications we have received)
f) Communicating with you about the recruitment process
Automated decision-making: Our recruitment processes may include the use of automated decision-making procedures (see Section 6 for further details).
Types of Data: This will require us to use your: (a) Identity; (b) Employment and Qualification Data; (c) Contact Data; (d) Profile Data; and (e) Usage Data.
Basis for processing: This processing is both necessary for us to comply with our legal obligations and in accordance with our legitimate interests (to ensure that our recruitment practices help us attract and retain the best employees).
Third-Parties Involved: We use Recruitment Agencies, who provide us with details of prospective candidates, as well as selected third-parties involved with:
a) Online platform providers for our testing and recruitment processes
b) Application screening (which may include the use of third-parties who are recruitment specialists in different sectors, such as logistics)
c) The completion of background checks
d) Conducting interviews
2. Carrying out background and reference checks, where applicable: This may include criminal background checks as well as checking education qualifications and employment history.
Types of Data: This will require us to use your: (a) Identity; (b) Employment and Qualification Data; and (c) Contact Data.
Basis for processing: This processing is both necessary for us to comply with our legal obligations and in accordance with our legitimate interests (to ensure that our recruitment practices help us attract and retain the best employees).
Third-Parties Involved: Selected third-parties involved with the completion of such background checks (including the Disclosure and Barring Service and Disclosure Scotland). Any third-parties which you specify as referees.
3. Processing information about criminal convictions: We may process information about criminal convictions if we consider it necessary for the role or are otherwise legally required to carry out such checks. This will be assessed on a role-by-role basis. More detailed checks may be required for those roles which involve a high degree of trust, such as those involving the handling or transfer of significant amounts of money.
Types of Data: This will require us to use your: (a) Identity; (b) Contact Data and (c) “Special Category” Data.
Basis for processing: This processing is necessary for us to comply with our legal obligations and in accordance with our legitimate interests (to ensure that our recruitment practices help us attract and retain the best employees).
Third-Parties Involved: Selected third-parties involved with the completion of such criminal conviction checks (including the Disclosure and Barring Service and Disclosure Scotland).
4. Processing other sensitive “Special Category Data”: We may use your special category data to:
a) Consider whether we need to provide appropriate adjustments during the recruitment process, for example whether reasonable adjustments need to be made: (i) during a test or interview; or (ii) to the role itself
b) Contact you to discuss any such adjustments;
c) Ensure meaningful equal opportunity monitoring and reporting
Types of Data: This will require us to use your: (a) Identity; (b) Contact; and (c) “Special Category” Data.
Basis for processing: This processing is necessary for us to comply with our legal obligations. We may also process such data on an anonymised basis, so that it cannot be linked back to you.
Third-Parties Involved: Selected third-parties involved with making the adjustments referred to above. You may be contacted directly by such third-parties to discuss the scope of those adjustments.
5. Data Analytics: To use data analytics to improve our Website and recruitment process.
Types of Data: This will require us to use your: (a) Technical; and (b) Usage data.
Basis for processing: This processing is in accordance with our legitimate interests (to keep our Website updated and to develop our recruitment processes).
Third-Parties Involved: Selected third-parties involved with:
a) The development of our Website
b) The development of our recruitment processes
c) Data analytics
6. Managing our relationship: To manage our relationship with you, which will include:
a) Registering you as a user of our Website
b) Managing feedback in respect of our recruitment process (including dealing with any queries or complaints)
c) Providing you with the information that you request from us
d) Keeping records of our relationship and recruitment practices
Types of Data: This will require us to use your: (a) Identity; (b) Employment and Qualification Data; (c) Contact Data; (d) Profile Data; (e) Technical Data; and (f) Usage Data.
Basis for processing: This processing is: (a) necessary for the performance of a contract with you; (b) necessary to comply with our legal obligations; and (c) in accordance with our legitimate interests (to keep our Website updated, to develop our recruitment processes and to keep our records updated).
Third-Parties Involved: Selected third-parties involved with managing and developing our recruitment processes.
7. Business Administration and Security: To administer and protect our business, and the Website, which will include:
a) Improving our Website to ensure that content is presented in the most effective manner for you and for your device
b) Allowing you to participate in interactive features of our Website
c) Troubleshooting and system administration
d) Data analysis and research
e) Testing and system maintenance
f) Usability assessment and improvement
g) Accessibility assessment and improvement
h) Technical support and reporting
i) Hosting of data
Types of Data: This will require us to use your: (a) Identity; (b) Employment and Qualification Data; (c) Contact Data; (d) Technical Data; (e) Profile Data; (f) Usage Data; and (g) “Special Category” Data.
Basis for processing: This processing is both necessary for us to comply with our legal obligations and in accordance with our legitimate interests (for running our business, the provision of administration and IT services, managing our network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
Third-Parties Involved: Selected third-parties involved with:
a) The development of our Website
b) The development of our recruitment processes
c) The encryption of data
Digraph Transport Supplies Ltd has 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.
If your application is unsuccessful, Digraph Transport Supplies Ltd may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
Who has access to data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment 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 not share your data with third parties, unless 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, our external provider for confidentially storing your information and processing payroll and pension or benefits providers where necessary.
International Transfers
The data that we collect from you will be stored on secure servers within the European Economic Area ("EEA") The majority of such data is held within the UK.
Certain information may be accessed and processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of background checks and support services.
We may also share your personal data within the Digraph Group (as defined above). This may also involve transferring your data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
The transfer will be to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission
We will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe
Where we use providers based in the US, we may transfer data to them if they are part of the “Privacy Shield” scheme which requires them to provide similar protection to personal data shared between the Europe and the USA
How does Digraph Transport Supplies Ltd protect data?
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
For how long does Digraph Transport Supplies Ltd keep data?
If you have been put forwards as an applicant for employment and you are unsuccessful then your data will be stored for 12 months you will be asked when you submit your CV whether you give us consent to hold your details in order to be considered for other positions or not.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper based) and retained during your employment. The Company will comply with statutory retention periods. Should you require further information on this please contact HR Department
Your rights
As a data subject, you have a number of rights. You can:
Access and obtain a copy of your data on request
Require the organisation to change incorrect or incomplete data
Require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
Object to the processing of your data where Digraph Transport Supplies Ltd is relying on its legitimate interests as the legal ground for processing
Withdrawing your consent to processing
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints
You have the right to make a complaint at any time to the local data protection supervisory authority which, for the UK, is the Information Commissioner's Office (ICO (www.ico.org.uk)). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to Digraph Transport Supplies Ltd 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.