Battersea Dogs & Cats Home (Battersea) Job Applicant Privacy Notice
As part of any recruitment process, Battersea collects and processes personal data relating to job applicants. We take the privacy of all those whose data we process very seriously and require all job applicants to carefully read this document. It contains important information about:
- Who we are;
- How and why we collect, store and use your information;
- How we keep your personal information safe and secure; and
- Your rights in relation to your personal information.
We are committed to bring transparent about how we collect and use your personal data and to maintaining a high level of data protection standards in all that we do.
Who are we?
Battersea Dogs and Cats Home is a company registered in England and Wales (company no. 278802) and a charity registered in England and Wales (charity no. 206304) whose registered office is at 4 Battersea Park Road, London, SW8 4AA. Our trading company, Battersea Dogs Home Limited (company no. 3472633), is wholly owned and controlled by Battersea Dogs and Cats Home, and together referred to in this policy as “Battersea”.
Battersea processes your personal data in accordance with the legal requirements set out in the following Data Protection legislation:
- Data Protection Act 2018 (DPA2018)
- General Data Protection Regulations (GDPR)
- Privacy and Electronic Communication Regulations (PECR)
Battersea uses one of the following lawful bases for processing your personal data:
- You have provided your consent;
- We are legally obliged to process your information;
- We believe it is in either Battersea’s or you the individual’s legitimate interest to do so; or
- There is a public interest for us to do so supported by law, for example safeguarding records.
The law sets out additional grounds for processing not listed above, that Battersea is not currently using. Any changes or additions to the grounds for processing in the future will be updated above.
How and why we collect, store and use your information?
Battersea collects different types of personal information about job applicants for various purposes. These are detailed in the sections below
What information does Battersea collect?
Battersea collect and processes 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;
- whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
- information about your criminal record if you have any unspent convictions;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, gender, health, age, and religion or belief
How does Battersea collect this information?
Battersea collects this information in a variety of ways. For example, data might be contained in application forms submitted through our applicant management system, from CV’s, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment including online tests.
Battersea will also collect personal data about you from third parties, such as references supplied by former employers and, for relevant roles, information from criminal records checks. We will only seek information from third parties once a job offer has been made to you and in all circumstances, inform you in advance.
Why does Battersea process personal data?
Battersea needs to process personal data to take steps at your request prior to entering into a contract with you, to comply with Battersea’s recruitment process. We also need to process your data at the stage of entering into a contract with you.
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts.
In other cases, Battersea has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process, as outlined in the lawful basis section below..
Lawful basis of processing
As discussed above, Battersea relies on one of 4 lawful bases to process the personal data of job applicants. The table below highlights which lawful basis is used for which activities:
To carry out pre-employment checks for successful applicants prior to them starting, such as DBS checks if applicable, or to confirm an individual’s right to work in the UK.
To check that successful candidates are statutorily allowed to the role they have applied for, such as checking a driver as a drivers licence, or that an accountant is qualified.
To process health information only at the stage of inviting a candidate in for an interview, so we can ensure reasonable adjustments have been identified where necessary and can be made. This is to carry out our obligations and exercise specific rights in relation to the Equality Act 2010.
To record Safeguarding concerns
To process special category data for equal opportunities and diversity monitoring. Data the Battersea collects is used for anonymous reporting, applicants are entirely free to decide whether or not to provide such data, and there are no consequences for failing to do so.
To send you email alerts about upcoming job opportunities that you have asked to receive. These can be stopped at any time. To communicate with you about possible future employment opportunities for which you may be suited if you are unsuccessful.
To manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide on whom to offer a job.
Where Battersea relies on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of employees or workers, and we have concluded that they are not. These assessments are reviewed on a regular basis, and if you any question on these, you can contact DataProtection@battersea.org.uk.
How do we keep your personal information secure?
Who has access to data?
Data will be stored in a range of different places, including on your application record, in Battersea’s applicant management system and on other IT systems (including Battersea’s email system).
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR team, the interview panel involved in the recruitment process, managers in the business area with a vacancy and other internal departments where necessary (such as sharing your name with security and reception staff when you are attending an interview).
If your application is successful and you are made an offer of employment, Battersea will also share your data with former employers to obtain references for you. For relevant roles, we will also share your data with the Disclosure and Barring Service to obtain necessary criminal records checks.
Battersea will not transfer your data outside the European Economic Area.
How does Battersea protect data?
Battersea takes the security of your data seriously. Battersea has internal policies, procedures and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.
Where Battersea engages with third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisations measures to ensure the security of data. We undertake due diligence and Data Protection Impact Assessments on any third parties we work with.
For how long does Battersea keep data?
If your application for employment is unsuccessful, Battersea will hold your data on file for seven months after the date of your last application for employment with Battersea. 30 days before the end of that period, you will be notified that your data is due for deletion and will have the option to choose for your data to be retained. If you do nothing, your data will be deleted at the end of the seven month period.
Where you opt in to receive job alerts from Battersea, you will be able to specify how long you wish to receive alerts for. If you wish to unsubscribe before the end of this period, you can do so via the ‘Unsubscribe’ link in any job alert email from Battersea. At the end of this period, you will automatically stop receiving job alerts. You can opt in again at any time via our website.
Your rights in relation to your personal information
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- request Battersea to change incorrect or incomplete data;
- request Battersea 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 Battersea is relying on its legitimate interests as the legal ground for processing; and
- ask Battersea to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the Battersea’s legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact DataProtection@battersea.org.uk .
If you believe that Battersea has not complied with your data protection rights, you can complain to the Information Commissioner (ICO) on 0303 123 1113 or through their website: www.ico.org.uk.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to Battersea during the recruitment process. However, if you do not provide the information, we will not be able to process your application properly or at all.
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.
How to contact us in relation to this Privacy Notice
If you have any questions about this Privacy Notice please contact the Compliance Manager or HR Team:
Compliance Manager: DataProtection@battersea.org.uk
HR Team: firstname.lastname@example.org
This Notice was last updated: December 2020