Privacy Policy

Who are we?

RecruitmentHub is an online recruitment service provided by HR Connect for Kent County Council.  HRConnect is a trading style of Commercial Services Kent Ltd (Reg No. 5858177), part of Commercial Services Group, a company wholly owned by Kent County Council and registered in England and Wales.

Commercial Services Group (CSG) is one of the largest, local authority owned, trading organisations of its kind in the UK.

Since its inception over 90 years ago as the supplies division of Kent County Council, it has grown organically to become one of the leading suppliers of products and services to the education and public sector, serving over 15,000 customers in 85+ countries.

CSG is the umbrella of all its trading brands, it provides the support, dependability, and security to allow all brands to thrive independently. CSG are committed to providing an excellent customer and user experience underpinned by social value and a committed and empowered workforce.

This notice explains what and why we collect personal information about people who apply for jobs using the system, what we do with this information, who will have access to it, who we pass your information on to, the length of time we keep your information and how to have your information removed.

In providing recruitment services to the recruiting organisation, HR Connect collects, uses and processes personal information about you. When we do so we are regulated under the UK Data Protection Act 2018 (DPA 2018) and the UK General Data Protection Regulation (UK GDPR).

• Where you are applying for a role with HR Connect we are responsible as a ‘controller’ of that personal information for the purposes of those laws.
• Where you are applying for a role with another organisation through the system, we are responsible as a ‘processor’ of that personal information for the purposes of those laws.

Please refer to each organisation’s privacy notice for further information:

· Kent County Council
· The Education People

Should you have any questions about this privacy notice please contact our Data Protection Officer at DPO@csltd.org.uk

 

About the information we collect, use and retain

The table below summarises the information we collect, use and retain, how and why we do so, how we use it and with whom it may be shared.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

 

The personal information we collect and use

The information we collect	How we collect the information	Lawful basis	How we use and may share the information
Name, email address and job alert preferences	From you when you create and update your account	At your request: to enable you to sign up and receive job alerts	To enable us to notify you of job opportunities in line with your job preferences
Contact information (e.g. name, address, phone number, email address)	From you via your application form, CV, personal statement and / or selection questions	Contractual obligations and requirements with the recruiting organisation(s)	Shared with the recruiting organisation to enable them to contact you to progress your application, arrange interviews and inform you of the outcome and issue any other correspondence required
Your reason for application / CV and covering letter, details of your qualifications, experience, employment history and interests	From you via your application form, CV, personal statement and / or selection questions	Contractual obligations and requirements with the recruiting organisation(s)	All fully completed applications will be shared with the recruiting organisation to enable them to make an informed recruitment decision. Please note that partially completed applications may be shared or viewed by the recruiting organisations. Details will be held against your job profile and your CV will be stored with the name and date of last post applied for
Equality and diversity information*	From you via a completed anonymised equal opportunities questionnaire	Contractual obligations and requirements with the recruiting organisation(s)	Shared with the recruiting organisation to enable them to comply with their equal opportunities monitoring obligations and to follow their equality and other policies
Declaration of disability*	From you via your application form	Contractual obligations and requirements with the recruiting organisation(s)	Shared with the recruiting organisation to enable them to comply with equal opportunities monitoring obligations and to follow equality and other policies To carry out a fair recruitment process including provision of reasonable adjustments if required
Information regarding your criminal record*	From you via your pre-employment tasks	Contractual obligations and requirements with the recruiting organisation(s)	Shared with the recruiting organisation to enable them to: · make an informed recruitment decision · carry out statutory checks · Information shared with the DBS and other regulatory authorities as required
Details of your referees	From you via your pre-employment tasks	Contractual obligations and requirements with the recruiting organisation(s)	Shared with the recruiting organisation to enable them to: · carry out a fair recruitment process · comply with legal/regulatory obligations

If you are offered a role, depending on the specific job requirements, you may be contacted for additional information needed to complete pre-employment checks and onboarding. This may include, but is not limited to: date of birth, NI number, bank details, student loan and tax declaration (to set up payroll), right to work status,  occupational health*, qualification, professional registration and DBS checks*

*We will comply with the additional conditions set out in the DPA 2018 and UK GDPR which relate to criminal convictions and sensitive personal information.

We also obtain personal information from other sources as follows:

• References from your referees
• Criminal records information from the Disclosure and Barring Service (DBS)
• Information regarding your educational and professional qualifications and registrations from the education provider, professional or registration body

As we have a statutory and contractual basis for collecting your personal data if you do not provide the following, when asked, we may be unable to progress your job application on behalf of the recruiting organisation.

• Personal Data: Title, Name(s), Address, Contact Details, Date of Birth, NI Number, Employment History, Qualifications/Memberships/Professional Registrations, Referee Details, Driving Licence Details, Bank Details, Tax Information, Student Loan Status, ID documents
• Personal Sensitive Data: Any Convictions, Cautions, Reprimands or Warnings, Nationality and Immigration Status, Occupational Health Information

We will share personal information with law enforcement or other authorities if required by applicable law.

We will share personal information with our professional advisers and use your information if it is necessary for the purposes of bringing or defending legal proceedings.

All fully completed applications will be shared with the recruiting organisation to enable them to make an informed recruitment decision.

Please note that partially completed applications may be shared or viewed by the recruiting organisations.

 

How we use your information to make automated decisions

An automated decision is where an electronic system makes a decision using personal information without human intervention (e.g. monitoring your online activities and emails or events which trigger actions such as your sickness absence triggering our capability policy). This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the services we may offer you now or in the future.

Automated decision making is allowed in the following circumstances:

1. Where we have notified you of the decision and given you 21 days to request a reconsideration
2. Where it is necessary to fulfil our contractual obligations and requirements and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit consent and where appropriate measures are in place to safeguard your rights.

If an automated decision is made, based on any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must put in place appropriate measures to safeguard your rights.

 

How long your personal data will be retained

We will not retain your personal information for longer than is reasonably necessary in providing the service or as is required by law. Upon expiry, any personal data which we are not legally obliged to retain, will be securely destroyed.

Your account will remain open indefinitely unless you close this.  Until such time as your account is closed, any personal data linked to your account will remain reportable.

 

When we will share your information

Other than as stated in the table above, we will share personal information with law enforcement, our regulators or other authorities if required by applicable law.

We will also share your personal information with third parties where it is necessary to administer our working relationship with the data controller or where we have another legitimate interest in doing so (providing this is not overridden by your interests).

We may also need to share some of the categories of personal information with other parties where a transfer of the business takes place. Usually, information will be anonymised or pseudonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations and legally binding data sharing agreements.

Our third-party service providers include:

•  Tribepad
•  EmploymentCheck (DBS Checks and Employment References)
• Cority (Occupational Health Checks)

Where information may be retained

Information may be retained at our offices and those of our service providers, representatives and agents as described above.

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection as in Europe. For further details, see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers/

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the European Economic Area (EEA).

 

Reliance on UK exemptions from the GDPR

We may use information in reliance on the exemptions under the DPA 2018 where allowed e.g. where a claim to legal professional privilege would apply, in relation to the provision of confidential references or for the purposes of management forecasting (to the extent that such forecasting would be prejudiced by advance notification).

 

Your Rights

Under the DPA 2018 and GDPR you have a number of rights which you can access free of charge which allow you to:

• Know what we are doing with your information and why we are doing it
• Ask to see what information we hold about you
• Ask us to correct any mistakes in the information we hold about you
• Object to direct marketing
• Make a complaint to the Information Commissioners Office

Depending on our reason for using your information you may also be entitled to:

• Ask us to delete information we hold about you
• Have your information transferred electronically to yourself or to another organisation
• Object to decisions being made that significantly affect you
• Object to how we are using your information
• Stop us using your information in certain ways

We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties.
Please note: your request may delay or prevent us delivering a service to you.

For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioners Office (ICO) on individuals’ rights under the General Data Protection Regulation. https://ico.org.uk/

If you would like to exercise a right, please contact DPO@csltd.org.uk or write  to Data Protection Officer, Commercial Services Group, 1 Abbey Wood Road, Kings Hill, West Malling, ME19 4YT.

 

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

Who to Contact

Please contact DPO@csltd.org.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.

You can contact our Data Protection Officer, at DPO@csltd.org.uk or by writing to Data Protection Officer, Commercial Services Group, 1 Abbey Wood Road, Kings Hill, West Malling, ME19 4YT.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone 03031 231113.

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.