Privacy Notice for Candidates
What is the purpose of this document?
Bullitt Group is committed to protecting the privacy and security of your personal information. This Privacy Notice describes how we collect and use personal information about you during our recruitment process, in accordance with the General Data Protection Regulation (GDPR).
Bullitt Group Limited is the Data Controller for the data you provide to us through the recruitment process, and is therefore responsible for deciding how it holds and uses personal information about you. Bullitt Group is required under data protection legislation to notify you of the information contained in this Privacy Notice.
It is important that you read this Privacy Notice, together with any other Privacy Notice Bullitt Group may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you
As part of all recruitment processes, Bullitt Group collects and processes personal data relating to job applicants and those registered for job alerts. We may even gain your contact details from publicly available information.
We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
We collect a range of information (including sensitive or special categories of personal information) about you when you apply for a role with us. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- details of your referees;
- whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
- criminal records information;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your gender, ethnic origin, age, sexual orientation, and religion or belief.
We collect this information in a variety of ways. For example, data might be contained in application forms, CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
We will also collect personal data about you from third parties, such as references supplied by former employers or other third-party referees, information from criminal records checks (if applicable to your role) and information from occupational health checks. We will seek information from third parties only once a conditional job offer to you has been made and you have accepted the offer.
How we will use information about you
We need to process data to take steps at your request prior to entering into a contract with you. We also need to process your data to enter into a contract with you.
In some cases, we need to process data to ensure that we are complying with legal obligations (including requirements of applicable employment laws). For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
We have 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. We may also need to process data from job applicants to respond to and defend against legal claims.
We may process other special categories of data, such as information about ethnic origin, sexual orientation, age, health or religion or belief, for equal opportunities monitoring purposes.
Where the processing would involve collecting, handling or storing sensitive or special categories of personal data, and we do not have an alternative lawful basis to rely on, we will seek your consent to do this. You are not obliged to provide consent, and where consent has been issued, you will be entitled to withdraw it at any time.
Our recruitment processes do not rely on automated decision-making.
Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection and recruitment of ex-offenders policy.
Less commonly, we may use information relating to criminal convictions where it is necessary in relation to
legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We do not envisage that we will hold information about criminal convictions as a matter of course.
However, from time to time and in certain circumstances, we may need to collect information about criminal convictions, but will only do so if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we would expect to collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.
Who has access to your data?
Your information will 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, payroll, audit, IT staff in order to set up systems access and any other internal department deemed necessary for your employment purposes.
We will share your data with third parties during the application period if the role you are applying for requires online assessments.
We will then only share your data with other third parties if 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, occupational health, and the Disclosure and Barring Service to obtain necessary criminal records checks (where applicable).
As part of making an application for a role with Bullitt Group, you acknowledge that we have a legitimate interest in sharing your personal information with the third parties stated above or any others deemed necessary for your offer of employment to be finalised.
Transferring information outside the EU
We may transfer your personal data outside of the United Kingdom and the EEA solely for the purposes of corresponding with you in relation to the role you have applied for.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Bullitt Group HR Team.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
If your application for employment is unsuccessful, we will hold your data on file for 6 months after the end of the relevant recruitment process.
At the end of that period (or if you make an earlier request to be removed), your data and any documents associated with you, shall be 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. Your personal data will then be subject to the terms of the appropriate Bullitt Group employee Privacy Notice (a copy of which will be made available to you upon commencing your employment).
Rights of access, correction, erasure, and restriction
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Any further queries
If you have any questions about this Privacy Notice or how we handle your personal information, please contact email@example.com in the first instance so we can help.
You have the right to make a complaint at any time to a national Data Protection Supervisory Authority. In the UK, this will be the Information Commissioner’s Office (ICO), whose address is Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Telephone 0303 123 1113.