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GDPR Candidate Privacy Notice (Effective 25 May 2018)
1. WHY DO WE HAVE THIS NOTICE?
Meteora Partners LLP is a data controller and is responsible for processing personal information about you. If you are applying for work with us (whether as an employee, worker or contractor) this notice applies to you. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for.
We are committed to complying with data protection law and have appointed a data protection officer (DPO) to oversee compliance. Any questions concerning this notice should be sent to the DPO by email at firstname.lastname@example.org.
2. WHAT INFORMATION MIGHT WE HOLD ABOUT YOU?
Personal data, or personal information, means any information about an individual from which that person can be identified.
In connection with your application for work with us, we may collect, store, and use some or all of the following categories of personal information about you:
• The information you have provided to us in your CV and covering letter, including, name, title, address, telephone number, personal email address, date of birth, employment history, educational qualifications, professional qualifications, references and other information collected as part of the application process.
• Any information you provide to us during the interview.
We may also collect, store and use the following categories of more sensitive personal information:
• Information about your health, including any medical condition.
• Information about criminal convictions and offences.
3. HOW IS THIS INFORMATION COLLECTED?
We collect personal information about you from the following sources:
• You, the candidate.
• If you have applied through a recruitment agency, from that recruitment agency.
• From third party databases such as Worldcheck.
4. HOW DO WE USE THIS INFORMATION?
We may use the personal information we collect about you to:
• Assess your skills, qualifications, and suitability for the position.
• Carry out background and reference checks, where applicable.
• Communicate with you about the recruitment process.
• Keep records related to our hiring processes.
• Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint you and to process your personal information to make this decision. We are also permitted to process this information to take steps prior to entering into any potential agreement with you.
5. HOW DO WE USE SENSITIVE PERSONAL INFORMATION?
We may use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process.
6. INFORMATION ABOUT CRIMINAL CONVICTIONS
We will collect information about your criminal convictions history if we would like to offer you the position, in order to assist us in making a decision about your recruitment or appointment (conditional on checks and any other conditions, such as references, being satisfactory). Given the nature of our services to our clients, your role requires a high degree of trust and integrity and so we are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.
7. AUTOMATED DECISION MAKING
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
8. DATA SHARING
We may have to share your data with third parties, (including third-party service providers) where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.
9. DATA SECURITY
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. We also have 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.
10. DATA RETENTION
We will retain your personal information for a maximum period of 8 months after we have communicated to you our decision about whether to appoint you to the position or as required by applicable law such as where we need to comply with a Resident Labour Market Test. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention provisions.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
11. 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.
• 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.
• Request the transfer of your personal information to another party.
12. FURTHER QUESTIONS OR COMPLAINTS
If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
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