Job applicant privacy notice

Introduction

  1. This job applicant privacy notice (“Privacy Notice“) is provided by Conrad Energy Limited (“we“, “us” and “our“), a private limited company registered in England and Wales at Suites D&E Windrush Court, Blacklands Way, Abingdon (Registration no. 09866059).
  2. References to “you” means any individual applying for a job with us and, where relevant, any dependants or other individuals about whom you provide Data in connection with your application to us.
  3. We are a “controller” for the purposes of the General Data Protection Regulation (EU) 2016/679 as it forms part of the law of England and Wales, Scotland and Northern Ireland (“GDPR“) and the Data Protection Act 2018 (collectively the “Data Protection Laws“). This means we determine the “how” and the “why” of the processing of your Personal Data. We are committed to protecting your privacy and processing your personal data fairly and lawfully in compliance with the Data Protection Laws.
  4. By “processing“, we mean the collection, recording, storage, use, disclosure and any other form of operations or dealings with your Personal Data.
  5. In the course of your application to us, we will need to collect and use “personal data” and “special categories of data” (collectively “Data“) about you as defined under the Data Protection Laws, by which we mean any information about you from which you can be identified. The aim of this Privacy Notice is to inform you of how we will process your Data provided in the course of you applying for a job with us and the measures and processes we have put in place to ensure its adequate protection.

What data do we collect about you?

  1. The sections below set out the categories of Data we may ask for at each stage of your application for a job with us. Some Data may not be required depending on the type of role you are applying for. The reasons why we need each category of data are set out in the section “How We Use Your Data“.
  2. If you choose not to provide us with any of these categories of information, your application may be rejected or it could affect our ability to process your application.
  3. Pre Application – If you contact us with any questions prior to submitting an application for a job, we will keep a record of your name and contact details, as well as details of any question you have asked
  4. If you submit an application or send us a CV – If you submit an application for a job with us, we will ask you for:
    • Your contact details, including your name, address, e-mail address and telephone number;
    • Details of your relevant education and employment history;
    • Details of referees; and
    • Additional information contained in your CV submitted to us.
  5. Assessment Stage – If you are successful in our initial shortlisting stage, we may invite you for an interview, assessment day, or to complete online tests. We will process Data generated by you and by us during this process. For example, you might complete written tests, undertake group exercises or we might take interview notes
  6. If we make you a conditional offer – If we make you a conditional offer of employment, we may collect further Data before deciding whether to make you a final offer, to check:
    • Proof of your identity;
    • Proof of your qualifications;
    • Pre-employment health questionnaire;
    • Credit check (role dependent); and
    • Right to Work checks.
  7. If we make and you accept a final offer – We will require further information from you in order to meet our obligations as an employer, such as your bank details so that we can pay your salary. How we process your information as an employee is set out in our Employee Privacy Notice which you will have access to when you start your employment.
  8. Personal information provided by third parties – Most of the Data we process about you when you apply for a job with us is information that you give us directly, or is generated through the recruitment exercise. However, some information we gather from the third parties is detailed below:
    1. Recruitment Agency: We fill some of our roles through recruitment agencies. If you apply for a role through them, they will pass us details of your name, contact details, CV, details of qualifications, right to work documentation, relevant experience and skills and/or notes of interview with the agency.
    2. Your former employer and other referees: If you apply for a role with us, we will contact your referees directly, using the details you provide in your application, to request a reference.

How we use your data

  1. We use your Data for the purposes listed in the table. We are allowed to do so on certain legal grounds which are also set out in the table (and which are explained further in the section “Fair and Lawful Processing“). 
Type of DataWhy do we need it?Lawful basis of processing
Contact details (name, email address, telephone number, home address)So that we can contact you about your application for a job with us.Legitimate interests
Necessary in order to take steps at your request prior to entering into a contract with you
Education and employment history, and proof of qualificationsSo that we can assess your relevant experience and suitability for a job with us, and assess what your training needs would be if you started working for us.Legitimate interests
Necessary for the decision on the establishment of an employment relationship
Information provided by professional and personal refereesSo that we can assess your relevant experience and suitability for a job with us.Legitimate interests
Necessary for the decision on the establishment of an employment relationship
Information about your regulatory or other professional membershipsSo that we can comply with our legal obligation (and obligation to our professional insurers) to make sure that individuals carrying out certain regulated roles are appropriately registered.Compliance with legal obligation
Information about your regulatory or other professional membershipsSo that we can assess your relevant experience and suitability for a job with us (where this is relevant for certain senior roles and/or where there is no legal requirement to be registered with a regulator).Legitimate interests
Identity documents such as a copy of your passport (including information about your national origin) or other right to work documentationSo that we can comply with our obligation to check that our employees have the right to work in the UK.Compliance with legal obligation
Information provided in our Equal Opportunities Monitoring form (such as information about your sexual orientation, racial origin and religion or belief)In order to promote and monitor diversity in our recruitment process. Information gathered for these purposes will be used anonymously for the purposes of assessing diversity statistics across the organisation, and will not be used as a basis for making any decisions about you. If you choose not to provide this information (or later decide you would like us to delete information you have already provided for this purpose), this will have no bearing on your application or employment with us.Substantial public interest – Equal opportunities monitoring purposes
Information about a disability which may affect the application processTo make reasonable adjustments to our application process for your disability.Compliance with legal obligation
Pre-employment health dataTo the extent permitted by applicable law, to determine whether you are medically able to carry out the work you have been offered, and to assess whether any adjustments are needed to the work environment to enable you to carry out that work.Compliance with legal obligation Necessary for assessing your working capacity as an employee.

Fair and lawful processing

  1. We have set out below a description about each of the legal grounds on which we process your Data.
  2. Processing of personal data:
    1. Necessary in order to take steps at your request prior to entering into a contract with you: We process some personal data if doing so is necessary in order to take steps prior to entering into a contract with you.
    2. Necessary for our legitimate interests: We process some personal data if doing so is in our legitimate interests as an employer. In order to do so, we have considered the impact on your interests and rights, and have put in place appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. You have the right to object to the processing of your personal data on this ground. See section headed “Your Rights” to find out how.
    3. Necessary for the compliance with a legal obligation: We have to process some of your personal data in order to comply with certain legal obligations.
  3. Processing of special categories of data:
    1. Necessary for compliance with our obligations under employment law: We have to process some special categories of data in order to comply with certain legal obligations.
    2. Necessary for substantial public interest: It is necessary for us to process special categories of data such as ethnic/religious background information for equal opportunities monitoring purposes. You have the right to object to the processing of your personal data on this ground. See section headed ‘Your Rights’ to found out how.
    3. Necessary for the purposes of occupational medicine, including the assessment of your working capacity as an employee: We will process information about your health in order to assess your medical capacity to perform the role you have applied for.
    4. Necessary to establish, exercise or defend legal claims: We will process special categories of data in order to exercise our legal rights and bring or defend claims.

When we may disclose your personal data

  1. We do not and will not sell, rent out or trade your Data. We will only disclose your Data in the ways set out in this notice and, in particular, to the following recipients:
    1. to a group company of Conrad Energy Limited; 
    2. to third parties who process your Personal Data on our behalf (such as our IT systems providers including cloud providers); 
    3. to legal advisors, security services and companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such information is shared; 
    4. to any third party to whom we assign or novate any of our rights or obligations; 
    5. to any prospective buyer in the event we sell any part of our business or assets; and/or 
    6. to any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request. 

How we protect your data

We are committed to safeguarding and protecting your Data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any Data provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Data transmitted, stored or otherwise processed.

International transfers of personal data

The Data we collect in connection with your application to us may be transferred to (including accessed in or stored in) a country or territory outside the UK or the European Economic Area (“EEA“), including to countries whose laws may not offer the same level of protection of personal data as are enjoyed within the UK and EEA. We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the Data Protection Laws.

Your rights

  1. As a data subject, you have the following rights under the Data Protection Laws:
    1. Right to object to processing of your personal data;
    2. Right of access to your personal data (known as data subject access request);
    3. Right to correct any mistakes in your personal data;
    4. Right to prevent your personal data being processed;
    5. Right to erasure of your personal data;
    6. Rights in relation to automated decision-making (not applicable); and
    7. Right to have your personal data ported to another controller (not applicable). 
  2. These rights are explained in more detail below. If you want to exercise any of your rights, please contact us (please see “How to contact us”).
  3. We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.
  4. Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in accordance with the Data Protection Laws.
  5. If your rights are breached by us you may be entitled to compensation for damage caused by contravention of the Data Protection Laws.
  6. Your data protection rights are further explained below:
Data Protection RightExplanation
Right to objectYou may object to us processing your personal data where we rely on a legitimate interest as our legal grounds for processing. If you object to us processing your personal data we must demonstrate compelling grounds for continuing to do so. We believe we have demonstrated compelling grounds in the section headed “How We Use Your Data”. The key point to note is that without processing your data, we will not know as much about you, which could affect our assessment of your suitability for a job with us.
Right to accessYou may ask to see what personal data we hold about you and be provided with:
• a copy of the personal data;
• details of the purpose for which the personal data is being or is to be processed;
• details of the recipients or classes of recipients to whom the personal data is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
• the period for which the personal data is held (or the criteria we use to determine how long it is held);
• any information available about the source of that data; and
• whether we carry out an automated decision-making, or profiling, and where we do information about the logic involved and the envisaged outcome or consequences of that decision or profiling.
To help us find the information easily, please provide us as much information as possible about the type of information you would like to see.
Right to correctYou can require us to correct any mistakes in your information which we hold. If you would like to do this, please let us know what information is incorrect and what it should be replaced with
Right to restrictYou may request that we stop processing your personal data temporarily if:
• you do not think that your data is accurate. We will start processing again once we have checked whether or not it is accurate;
• the processing is unlawful but you do not want us to erase your data;
• we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or
• you have objected to processing because you believe that your interests should override our legitimate interests.
Right to erasureYou can ask us to erase your personal data where:
• you do not believe that we need your data in order to process it for the purposes set out in this Privacy Notice;
• if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data;
• you object to our processing and we do not have any legitimate interests that mean we can continue to process your data; or
• your data has been processed unlawfully or has not been erased when it should have been.
Rights in relation to automated decision making (not applicable)We do not make any automated decisions about you so this right does not apply.
Right to data portability (not applicable)In some scenarios, you may ask for an electronic copy of your personal data which we hold electronically or you can ask us to provide this directly to another party. This right does not apply as we do not process your personal data based on your consent or under a contract with us.

How long we will hold your data for

  1. If your application for a job with us is unsuccessful or you do not accept our offer of employment, then we will delete all of the Data gathered during the recruitment exercise 12 months after the relevant recruitment exercise has ended.
  2. If your application for a job with us is successful and you start work as our employee, please see the Employee Privacy Notice for details of how long we will retain the Data gathered during the recruitment exercise. If you apply for a new role with us when you are already our employee, this Privacy Notice applies in respect of any new information gathered during that application process, and the Employee Privacy Notice continues to apply in respect of any information we already hold by virtue of you being a current employee.

How we update or change this privacy notice

We may change or update parts of this Privacy Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. If we make any significant changes to the way we process your data and/or this Privacy Notice, then we will notify you of such changes or updates.

How to contact us 

If you have any queries about the contents of this Privacy Notice, wish to inform us of a change or correction to your Data or would like this Privacy Notice in another format (for example: audio, large print, braille), would like a copy of the data we collect on you or would like to raise a complaint or comment, please contact us using the details set out below:

Email: info@conradenergy.co.uk
Post: Privacy Manager, Conrad Energy Limited, Suites D&E Windrush Court, Blacklands Way, Abingdon, OX14 1SY

How to lodge a complaint to the regulator

It is important that you ensure you have read this Privacy Notice – and if you do not think that we have processed your data in accordance with this notice – you should let us know as soon as possible. You may also complain to the ICO. Information about how to do this is available on its website at www.ico.org.uk.