Job Applicant Privacy Policy

• Data controller: QueryClick, Spaces Lochrin Square, 92-98 Fountainbridge, Edinburgh, EH3 9QA
• Data Protection Officer: RGDP, Level One, Edinburgh Quay, 133 Fountainbridge, Edinburgh, EH33 9QG. E-mail – [email protected]
• Data protection lead: Leeanne Weatherston, Head of HR, [email protected]

As part of any recruitment process, QueryClick collects and processes personal data relating to job applicants. QueryClick is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does QueryClick collect?

QueryClick collects 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;
• information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which QueryClick needs to make reasonable adjustments during the recruitment process; and
• information about your entitlement to work in the UK.

How does QueryClick collect information about you?

QueryClick may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

QueryClick use a third-party service provider to check your right to work in the UK. This includes performing checks to confirm your identity, by comparing your passport or driving licence photograph against your actual face, using facial recognition technology.

QueryClick may also collect personal data about you from third parties, such as references supplied by former employers. QueryClick 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 in a secured share and on other IT systems (including email).

Why does QueryClick process personal data?

QueryClick needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.

In some cases, QueryClick needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.

QueryClick has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows QueryClick to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. QueryClick may also need to process data from job applicants to respond to and defend against legal claims.

QueryClick may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. QueryClick processes such information to carry out its obligations and exercise specific rights in relation to employment.

For some roles, QueryClick is obliged to seek information about criminal convictions and offences. Where QueryClick seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, QueryClick may keep your personal data on file in case there are future employment opportunities for which you may be suited. QueryClick will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information may 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.

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

In relation to our third party service providers, we have in place a written contract which only permits them to process your data for specified purposes and in accordance with our instructions. All their employees must be subject to a duty of confidentiality. The contract also requires third party service providers to take appropriate security measures in relation to your personal data which are in line with our policies.

Your personal data may be transferred to countries outside the European Union if it is necessary as part of your job application process. Some of these countries do not have the relevant level of protection in place. QueryClick will ensure that an appropriate contract is in place with any third parties to whom data is transferred on a regular basis or it will rely on an appropriate legal exemption for such transfers.

How does QueryClick protect data?

Your personal data will be stored in a range of different places, including on your application record, in our human resources management systems in a secured shared area and on other IT systems (including email).

QueryClick takes the security of your data seriously. It has 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.

How long does QueryClick keep the data for?

If your application for employment is unsuccessful, QueryClick will hold your data on file for 12 months after the end of the relevant recruitment process. If you agree to allow QueryClick to keep your personal data on file, QueryClick will hold your data on file for future employment opportunities. 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. We will retain your data for the duration of your employment with us, and then for a further 6 years after your employment ends after which it will be securely destroyed unless there is a legitimate reason for retaining for a further period.

Your rights

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

• access and obtain a copy of your data on request;
• require QueryClick to change incorrect or incomplete data;
• require QueryClick to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
• object to the processing of your data where QueryClick is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights, please contact Leeanne Weatherston, Head of HR, [email protected].

If you believe that QueryClick has not complied with your data protection rights, you can complain to the Information Commissioner. Contact details are available at www.ico.org.uk

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to QueryClick during the recruitment process. However, if you do not provide the information, QueryClick may not be able to process your application properly or at all.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.

Data Subject Access Request Form

The General Data Protection Regulation and the UK Data Protection Act 2018 provide you with the Right to Access your own personal data held by QueryClick.

If you wish to make a Data Subject Access Request to us please complete the form below.

On receipt of your request, we will contact you to ask for proof of your identity. This is to ensure we do not release personal information to the wrong person.

When we receive a Subject Access Request, all efforts will be made to fully comply within one month of receipt of your request. If we are unable to comply with your request within one month we will inform you and explain why the extension is necessary.

CHANGES TO THIS PRIVACY NOTICE

QueryClick reserves the right to update this privacy notice at any time and will provide you with a new notice when making any substantial updates. QueryClick may also notify you in other ways from time to time about the processing of your personal data.

MONITORING AND REVIEW

This policy was last updated on November 2022 and shall be regularly monitored and reviewed, at least every two years.