We at Distinctive People are committed to protecting the privacy of our job applicants, candidates, clients and suppliers; being transparent about how we collect and use personal data; and in meeting our data protection obligations.
This policy covers the core information required under the General Data Protection Regulations ((EU) 2016/679). It sets out how and why your personal data will be used, namely for the purposes of Recruitment, HR and OD services, and how long it will usually be retained for. The policy applies to all job applicants, candidates, suppliers and clients accessing our services.
Distinctive People Ltd (Company Registration Number 09838681) is the Data Controller and our Data Protection Officer is Mark Glinwood. We can be contacted on 0203 887 0663 or firstname.lastname@example.org
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
What personal data do we collect about you?
We collect and use only the information necessary for us to carry out our recruitment processes effectively, and to assess your eligibility through the different stages of recruitment. This includes:
We may also collect, store and use the following “special categories” of more sensitive personal information:
We will only collect sensitive personal data from you, and further process this data, where you have given your explicit consent
Why do we collect personal data?
The organisation 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 the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims
How is your personal data collected?
We may collect this information from a number of sources, including:
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).
How do we use your personal data?
We will use the personal information we collect about you to:
We will use your particularly sensitive personal information in the following ways:
Automated decision making
We do not use automated decision making in any part of our recruitment process.
How long do we keep your personal data for?
We will only retain your information for as long as is necessary for us to use your information as described above, or to comply with our legal obligations
We will retain your personal information for a period of 6 months after we have communicated to you our client’s decision about whether to appoint you to the role. 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 procedure and applicable laws and regulations.
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.
Who do we share your personal data with?
We will only share your personal information with third parties, such as our clients or suppliers, for the purposes of processing your application and carrying out recruitment processes.
All our third-party clients or suppliers are required to take appropriate security measures to protect your personal information in line with our policies. We only permit our clients or suppliers to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties may be based outside the European Economic Area (EEA) so their processing of your personal information may involve a transfer of information outside the EEA. We do not share your personal information with third parties unless we are required to do so by law or where you have consented to us sharing your information. We may share your personal information with certain trusted third parties in accordance with certain contractual obligations that we have with them and to assist us in providing you with our services, including: IT service and cloud-based storage providers.
The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will take reasonable steps to implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us 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.
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 do we safeguard your personal data?
We take the security of your data very seriously and have put in place appropriate measures that are designed to prevent unauthorised access to or misuse of your personal data.
In addition, we limit access to your personal information to those employees, and third-party clients or suppliers who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place 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.
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data:
If you would like to exercise any of these rights, please contact Mark Glinwood on email@example.com
If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.
Distinctive People Data Protection Policy
Job Applicant Privacy Notice: