Recruitment Privacy Notice 

Joint Waste Solutions Privacy Notice

As part of any recruitment process, Joint Waste Solutions (JWS) and its host authority, Surrey Heath Borough Council (SHBC), collects and processes personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.

What information does JWS and SHBC collect?

We collect a range of information about you. This includes the following points:

  • your name, address and contact details, including email address, telephone number;
  • details of your qualifications, skills, experience and employment history;
  • whether or not you have a disability for which we need to make reasonable; and
  • adjustments during the recruitment process; and information about your entitlement to work in the UK;

JWS and SHBC collects this information in a variety of ways. For example, data is collected via Jobs Go Public in the online application forms, CV’s or resumes.

JWS and SHBC also collect data at the point of job offer, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

JWS and SHBC will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. JWS and SHBC will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

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

Why does JWS and SHBC process personal data?

JWS and SHBC 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.  Our lawful basis for processing is therefore ‘necessary for contract’.

In some cases, JWS and SHBC need to process data to ensure that we are complying with our legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.

JWS and SHBC have a lawful basis for processing personal data during the recruitment process under the condition of ‘necessary for contract’ and for keeping records of the process. Data is anonymised for the purpose of shortlisting to interview stage, however further processing enables 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.

JWS and SHBC process health information if we need 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 JWS and SHBC process other special categories of data (sensitive personal data), such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes. This is optional and can be collected at the beginning of the recruitment process or at the point of offering the role.

For some roles, JWS and SHBC are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.  Employment law and health/social care are categorised as special categories of data under Article 9 of the General Data Protection Regulation (GDPR).

JWS and SHBC will not use your data for any purpose other than the recruitment exercise for which you have applied.

Who has access to 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 and IT staff if access to the data is necessary for the performance of their roles.

JWS and SHBC will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. JWS and SHBC will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background check and the Disclosure and Barring Service and Disclosure Scotland to obtain necessary criminal records checks.

JWS and SHBC will not transfer your data outside the European Economic Area.

How does JWS and SHBC protect data?

JWS and SHBC takes the security of your data seriously. We have 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.  SHBC has an Information Security Policy and Data Protection Policy which details how the IT systems and data are managed and who has access.  The Data Breaches Policy explains how the Council will handle any potential breach.

For how long does JWS and SHBC keep data?

If your application for employment is unsuccessful, JWS and SHBC will hold your data on file for 6 months after the end of the relevant recruitment process. At the end of that 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 data will be held will be available to you in a new Privacy Notice.

Your rights

As a data subject, you have a number of rights. You have:

  1. The right to be informed
  2. The right of access
  3. The right to rectification
  4. The right to erasure
  5. The right to restrict processing
  6. The right to data portability
  7. The right to object
  8. Rights in relation to automated decision making and profiling.

If you believe that JWS and SHBC has not complied with your data protection rights, you can complain to the Information Commissioner www.ico.gov.uk or casework@ico.org.uk. You are under no statutory or contractual obligation to provide data to JWS and SHBC during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

What if you do not provide personal data?

If you would like to exercise any of these rights, please contact data.protection@surreyheath.gov.uk . You can make a subject access request by requesting the Council’s form for making a subject access request.