Job applicant privacy notice

Data controller: Livelyhood Venues Ltd, Office 36, Hideaway Work Space, 1 Empire Mews, Streatham, SW16 2BF

Contact details: If you have any questions about this job applicant privacy notice please contact Human Resources – hr@livelyhood.co.uk

The General Data Protection Regulation (GDPR) requires employers to be transparent about the personal data that they hold and how it is used and Livelyhood Venues Ltd (referred to as “the company” throughout this notice) is committed to being transparent about how we collect and process personal data relating to job applicants as part of any recruitment process and committed to meeting its data protection obligations.

This notice sets out the basis on which we collect, use and disclose the personal data of our job applicants, as well as your rights in respect of such personal data.

What information does the company collect as part of any recruitment process?

The company collects a range of information about you. This includes:-

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information from interviews, work trials, or phone screenings you may have;
• information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.

The company collects this information in a variety of ways. For example, data might be contained in cover letters, CVs or resumes, (including when these are sent to us or dropped into one of our sites as part of speculative applications or queries) obtained from your passport or other identity documents, or collected through interviews or other forms of selection, including trial shifts.

The company will also collect personal data about you from third parties, such as references supplied by former employers, academic references or in some cases character references, information from recruitment agencies and for management appointments only, information from criminal records checks collected via basic online disclosures, which will only be sought once a management job offer has been made.

The company will seek reference information from third parties only once it has informed you that it is doing so.

Data will be stored in a range of different places, including on your application record, in management systems and on other IT systems (including email).

Why does the company process personal data as part of any recruitment process?

The company needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.

In some cases, the company needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.

The company 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 the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment, decide to whom to offer a job and, if an offer is made, to decide upon the terms of any offer. The company may also need to process data from job applicants to respond to and defend against legal claims.

Where the company relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

The company processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

Where the company processes other special categories of data, such as information about ethnic origin, sexual orientation, health, religion or belief, age, gender or marital status, this is done for the purposes of equal opportunities monitoring with the explicit consent of job applicants, which can be withdrawn at any time.

We will not use your data for any purpose other than the recruitment process of which you are a part.

For all management level roles, only once a job offer has been made, the company seeks information about criminal convictions and offences via a basic online disclosure check. The company considers that it is in our legitimate interests for management appointments to collect and process the information gathered from basic online disclosure checks in order to decide whether to appoint you to a management role within the company.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR team, interviewers involved in the recruitment process and managers in the business area with a vacancy.

The company will seek reference information from third parties only once it has informed you that it is doing so. The company will then share your data with former employers/other agreed referees to obtain references for you.

The company will not transfer your data outside the European Economic Area.

How does the company protect data?

The company takes the security of your data seriously. It has 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 the company keep data?

If your application for employment is unsuccessful, (including when you have speculatively applied to us in respect of a role which is not available) the company will hold your data on file for six months after the end of the relevant recruitment process (or 6 months after the application was submitted for speculative applications)

We retain your personal information for six months so that we can show, in the event of a legal claim, that we have conducted the recruitment exercise in a fair and transparent way.

At the end of that period, your data is deleted or destroyed (unless we need to retain it for longer to exercise or defend any legal claims).
If you request the company to retain your personal data on file, the company will hold your data on file for a further six months for consideration for future employment opportunities. At the end of that total 12 month period, or once you withdraw your consent, your data is deleted or destroyed

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your employment data will be held will be provided to you in a new privacy notice.

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 company to change incorrect or incomplete data;
• require the company 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 the company is relying on its legitimate interests as the legal ground for processing; and
• ask the company to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the company’s legitimate grounds for processing data.

If you would like to exercise any of these rights or if you have any questions about this notice or our processing of your data more generally, please contact Human Resources at hr@livelyhood.co.uk. If you believe that the company has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the company during the recruitment process. However, if you do not provide the information which is requested and which is necessary for us to consider your application (such as work history), the company may not be able to process your application properly or at all.

For example, if we require references for the role and you fail to provide us with relevant details, we will not be able to take your application further.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

Automated decision-making

Our recruitment processes are not based on automated decision-making.

How we keep this notice up to date

We will review and update this notice from time to time. This may be to reflect a change in our internal procedures or it may be to reflect a change in the law.

Each time we update our notice we will update the notice version number shown at the end of the notice.

This is notice version 1.0.