THE BON VIVANT GROUP CANDIDATE PRIVACY POLICY
Data controller: Devil’s Advocate Limited
Data protection officer: People and Culture Director
As part of any recruitment process, the organisation collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does the organisation collect?
The organisation 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 the organisation needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.
The organisation collects 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, including online tests.
The organisation 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. The organisation 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 the organisation process personal data?
The organisation needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, the organisation 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.
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.
Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
The organisation processes health information if it needs 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 the organisation processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.
For some roles, the organisation is obliged to seek information about criminal convictions and offences. Where the organisation 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.
The organisation 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.
The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation 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 to obtain necessary criminal records checks, when applicable.
The organisation will not transfer your data outside the European Economic Area.
How does the organisation protect data?
The organisation 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.
For how long does the organisation keep data?
We will keep your account data for so long as your account is active, and for 6 months after the date of your last login. Where you submit a CV, we will keep this for up to 6 months after the date of your application, irrespective of whether you are successful (and may keep for longer if you elect to be part of our Talent Pool, see below). Data subject requests (including a request to delete your account) may be submitted through the “account settings” section of your account.
Where you sign up for text alerts about job vacancies, we will keep the details of your phone number for 3 months, after which time such data will be deleted. If you would like your phone number to be deleted prior to the end of the standard 3 month period (or for any other data subject requests in relation to such data) please contact our Data Protection Officer at the email address in the first paragraph above.
Once data is deleted it will cycle through our usual backup processes for a period.
Talent Pool
Where you have elected to join our Talent Pool:
• all your personal data, including CV and all applications (live and closed) associated with your accountwill be retained in the Talent Pool until the earlier of (i) the date falling 6 months from the date on which your CV is submitted to the Talent Pool, (unless at that point in time you consent to it remaining in the Talent Pool for another 6 month period); and (2) the date on which you request that your personal data is removed, which you may do by submitting a Data Subject request for deletion through the “accounts setting” section of the Site.
• all your personal data, including CV and all applications (live and closed) associated with your account will also be removed from the Talent Pool if and when an application is successful and you become an employee.
Note that the data retention for Talent Pool data described above is separate from, and independent of, the data retention policies which apply to your data which you submit to the Site (see above under “Retention of Data on the Site” for more detail on those retention periods).
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 the organisation to change incorrect or incomplete data;
• require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and
• ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation’s legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact Marzena D’Arcy, People and Culture Director at marzena@chrisstewartgroup.com
If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation 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.
Automated decision-making
Recruitment processes are not based solely on automated decision-making.
