What do we mean by “personal data” and “processing”?
“Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you, but also intentions and opinions about you. “Processing” means doing anything with the data. For example, it includes collecting it, holding it, disclosing it and deleting it. Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by EU privacy law to be “sensitive personal data”.
Your personal data
We process your data for the purposes of fulfilling our recruitment practices. Some of the personal data that we process about you comes from you. For example, you tell us your contact details. Other personal data about you is generated from references and third party companies such as recruitment agencies. Your personal data will be seen internally by managers, administrative assistants to HR/hiring managers, payroll, IT, HR and relevant third parties. You are not obliged to provide us with this data. However, not doing so may adversely affect your chances of recruitment.
How long do we keep your personal data?
If you are successful in your application your data will be kept on your personnel file. If you are unsuccessful, your data will normally be destroyed 12 months after you have been informed that you were unsuccessful. Irrelevant data such as CCTV images may be deleted after a short period.
Legal grounds for processing personal data
What are the grounds for processing?
Under data protection law, there are various grounds on which we can rely when processing your personal data. In some contexts more than one ground applies. We have summarised certain grounds as Legal obligation and Legitimate Interests and outline what those terms mean below.
Term Ground for processing Explanation
Contract Processing necessary for performance of a contract with you or to take steps at your request to enter a contract This covers carrying out our contractual duties and exercising our contractual rights. Legal obligation Processing necessary to comply with our legal obligations Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination Legitimate Interests Processing necessary for our or a third party’s legitimate interests. We or a third party have legitimate interests in carrying out, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data. Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.
Processing sensitive personal data
If we process sensitive personal data about you, as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one or more of the grounds for processing sensitive personal data applies, including that the processing is for equality and diversity purposes to the extent permitted by law. Further information on the data we process and our purposes Examples of the data and the grounds on which we process data are in the table below.