Sargeant Partnership is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you as part of our candidate application and recruitment activities, in accordance with the General Data Protection Regulation (GDPR).
Sargeant Partnership is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
We collect, process and store personal and special categories of data which may directly or indirectly identify you (together “personal information”). We process personal information for a range of purposes relating to general recruitment activities as well as the recruitment process and this may include your application, assessment, pre-employment screening, and any worker permissions.
This Candidate Privacy Notice (“Privacy Notice”) sets out:
- Why we collect your personal information;
- What information is collected and;
- How it is processed within the recruitment process.
Throughout this Privacy Notice we use the term “processing” to cover all activities involving your personal information, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of the information.
Why do we collect your personal information?
We only process your personal information where we are lawfully permitted for one or more of the purposes set out below. Not all of the purposes set out below will apply to you all of the time.
- Application:activities carried out in the course of receiving and assessing candidate applications, including reviewing general applications or applications for specific jobs and processing information to enable subscription to our job alerts. This may involve the processing of your CV, name, address, employment history, academic and professional qualifications, age, diversity data including gender, ethnicity, disability, sexual orientation, nationality and previous disciplinary matters;
- Assessment:activities carried out in the course of assessing candidate suitability for roles at the bank, which may involve the processing of your CV, psychometric tests (such as a situational judgement test, ability or personality test), interview (face to face, telephone or video), behavioural assessments (such as a role play, group exercise or presentation), technical assessments;
- Pre-employment screening (PES):pre-employment screening activities carried out for the purposes of financial, credit history and insurance risk assessments; criminal records checks; county court judgements checks, adverse media checks;
- Candidate searches:in the course of our search activities, we use personal information that we have collected concerning candidates to identify professional opportunities that we think may be of interest. We may contact potential candidates from time to time regarding such opportunities. We may also contact individuals from time to time to solicit names of, or other personal information regarding, potential candidates in connection with a search that we are conducting and for purposes of market intelligence;
- General recruitment activities:market research activities and specific or speculative recruitment-related activities.
What personal information might we process and how we collect it?
Generally, we collect personal information directly from you in circumstances where you provide personal information to us by applying directly for a role at the partnership, or information that we learn about you through your interactions with us, or with third parties (e.g. recruitment agencies). We may also collect personal information about you from third parties, including, for example, when a referee provides information about you, when a colleague recommends that we consider you for a position or from other sources where you have made your personal information publically available for the purposes of recruitment on jobs boards, LinkedIn (or other publically available social media networks and databases). Here are some examples of the type of information we may process about you. There’s a full list in Schedule 1 at the end of this Privacy Notice.
- a) Your Personal Information
b) Your Special Categories of Information
- Personal details such as name, address, email address and date and place of birth;
- Work history/job data; previous employers, positions, dates, etc.;
- Compensation; basic salary, benefits, bonuses, etc.;
- Education and work history including professional qualifications and skills;
- Employer feedback / references, to include regulated references where necessary;
- Nationality / visa / right to work permit information; (e.g. passport, driving licence, National Insurance numbers);
- Results of pre-employment screening checks (e.g. credit history, criminal records checks where permitted under local law);
- Assessment results e.g. psychometric assessment results, results from gamification and video or telephone assessment.
During the process we may also inadvertently capture some special categories of personal information about you (e.g. information relating to your racial or ethnic origin, religious of philosophical beliefs, trade union membership, physical or mental health or condition, sexual orientation), where this has been provided or made publically available by you or can be inferred from your CV.
We may also process certain special categories of information about you (e.g. information about a physical or mental health or condition) in order to make reasonable adjustments to enable our candidates to apply for jobs with us, to be able to take online/telephone assessments, to attend interviews/assessment centres, to prepare for starting with us (if successful) and to ensure that we comply with regulatory obligations placed on us with regard to our hiring. We may also process information relating to criminal convictions and offences (e.g. as part of pre-employment screening checks). We will only process special categories of information or information about criminal convictions and offences where we have obtained your explicit consent or where permitted by applicable laws (and then only when necessary for the purposes mentioned above). Where we are processing personal information based on your consent, you have the right to withdraw that consent at any time where there is no other legal basis for the processing.
Legal basis for the processing
Our entitlement to process your personal information is governed by a number of processing conditions. This means that we may rely on more than one of these conditions in order to process elements of your personal information throughout the recruitment process.
- It is in the legitimate interests of the partnership to process your personal information in the administration of your application and for general recruitment purposes;
- We will also process your personal information where it is required by law or regulation. This processing will always be fair and lawful and will at all times comply with the principles of applicable privacy laws in the country where you have applied to be employed;
- During the course of your application it may also be necessary for us or our suppliers to process special categories of information about you where we have obtained your explicit consent or where permitted by applicable laws.
How we will use information about you?
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role
- Carry out background and reference checks, where applicable
- Communicate with you about the recruitment process
- Keep records related to our hiring processes
- Comply with legal or regulatory requirements
It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role.
We also need to process your personal information to decide whether to enter into a contract of employment with you.
Having received your application, we will process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references before confirming your appointment.
Who do we share your personal information with?
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.
We may also need to share your information with certain external third parties including:
- Companies who provide recruitment and candidate interview and assessment services to us;
- Suppliers who undertake background screening on our behalf (credit checking agencies, criminal checking bureaus, etc.);
- Academic institutions (Universities, colleges, etc.) in validating information you’ve provided;
- Individuals and companies that you have previously worked for who may provide references/recommendations to us;
Other third-party suppliers (or potential suppliers), who provide services on our behalf such as payroll, pension administration, benefits provision and administration, IT, HR and Legal services.
The partnership will not transfer your data outside the European Economic Area.
How do we protect your information?
The partnership 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.
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.
For how long do we keep your data?
If your application for employment is unsuccessful, we will hold your data on file for up to 12 months after the end of the relevant recruitment process. If you agree to allow us to keep your personal data on file, we will hold your data on file for a further 12 months for consideration 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. The periods for which your data will be held will be provided to you in a new privacy notice.
- a) Access, correction and deletion
You are entitled to see the personal information we hold about you. You can also request changes to be made to incorrect personal information and can ask for your personal information to be deleted or blocked if you legitimately think that we shouldn’t be processing that information or is processing it incorrectly, except where retention of that personal information is required in the context of a legal dispute, or as otherwise required by law. If access, correction or deletion is denied, the reason for doing so will be communicated to you.
- b) Inquiries, objections and complaints
If you have any queries about this notice or your personal information generally, including questions about accessing your personal information or correcting it, you should contact Elaine Pavis in writing at Elaine.Pavis@sargeantpartnership.com in the first instance. You may also withdraw consent to the processing of your personal information or submit complaints and/or objections to the processing of your personal information by sending a request in writing to Elaine Pavis at Elaine.Pavis@sargeantpartnership.com.
- c) Automated processing
We do not generally make recruiting or hiring decisions based solely on automated decision-making. In the event that we rely solely on automated decision-making that could have a significant impact on you (e.g. automated psychometric and behavioural testing), we will provide you an opportunity to express your views and will provide any other safeguards required by law.
- d) Direct Marketing
We will not use personal information collected about you for the purposes of recruitment to offer you any products or services for personal or family consumption (“direct marketing”) or provide your personal information to third parties for their direct marketing. We will ask for your consent prior to sending you communications about future events and opportunities that are relevant to you.
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 fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
Schedule 1: Full list of information we may process
- Name, work and home contact details
- Date and place of birth
- Education and work history
- Individual demographic information in compliance with legal requirements (such as marital status, national identifier, passport/visa information, nationality, citizenship, military service, disability, work permit, date and place of birth or gender)
- Health issues requiring adaptations to working environment
- Job title, grade and job history
- Employment contract related information (including compensation, location, hours of work and so on)
- Reporting and managerial relationships
- Leaves of absence (such as maternity leave, sickness absence)
- Disciplinary / grievance records
- Time and attendance details
- Bank account details for salary payment purposes
- Expenses such as travel and expenses claimed
- Personal information contained in CVs (e.g. name, address, telephone number, e-mail address, employment history, degree(s) and other qualifications, languages and other skills). These may also include, without limitation: age, nationality and race (only to the extent allowed by law), compensation details, a record of our contact history with you and comments from third parties
- Skills and qualifications
- Personal information which you have made available for the purposes of recruitment on jobs boards, LinkedIn (or other publically available social media networks) and to third parties such as recruitment agencies that we work closely with
- Training history and plans
- Results of original and ongoing employee screening, where relevant
- Details provided in relation to Conduct policies (such as conflicts of interest, personal account dealing, trade body membership and so on)
- Health & safety incidents, accidents at work and associated records
- Audio recordings of telephone interviews
- Notes from face to face interviews
- Psychometric test results and associated reports
- Results from behavioural assessments
- Results from technical assessments
- References and recommendations