Job Applicant Privacy Statement

YMCA Trinity Group is aware of its obligations under the Data Protection Act and is committed to processing your data securely and transparently. This privacy statement sets out the types of data that we collect and hold on you as a job applicant. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

Data controller details

YMCA Trinity Group is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows:

Queen Anne House Gonville Place Cambridge Cambridgeshire CB1 1ND

Data protection principles

In relation to your personal data, we will:

• process it fairly, lawfully and in a clear, transparent way
• collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
• only use it in the way that we have told you about
• ensure it is correct and up to date
• keep your data for only as long as we need it
• process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed

Types of data we process

Through your application form we hold many types of data about you, including:

• your personal details including your name, address, date of birth, email address, phone numbers
• your photograph
• gender
• marital status
• ethnicity
• whether or not you have a disability
• information included on your CV/application including references, education history and employment history
• documentation relating to your right to work in the UK
• driving licence
• criminal record or DBS registration number, following a Disclosure and Barring Service check (for applicable roles)
• copies of qualifications and other certificates

How we collect your data

We collect data about you via your application form, this is hosted by a third- party webhost, Talos360. Their Privacy Notice is available via the link below. Our recruiting officers may also make notes using data you share during a recruitment interview. Further information will be collected directly from you when you complete forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references.

Personal data is kept in personnel files or within YMCA Trinity Group’s HR and IT

systems, these are cloud based.

Why we process your data

The law on data protection allows us to process your data for certain reasons only:

• in order to perform the employment contract that we are party to
• in order to carry out legally required duties
• in order for us to carry out our legitimate interests
• to protect your interests and
• where something is done in the public interest.

All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.

We need to collect your data to ensure we are complying with legal requirements such as:

• carrying out checks in relation to your right to work in the UK
• carrying out disclosure and barring service checks
• making reasonable adjustments for disabled employees.

We also collect data so that we can carry out activities which are in the legitimate interests of YMCA Trinity Group. We have set these out below:

• making decisions about who to offer employment to
• making decisions about salary and other benefits
• assessing training needs
• dealing with legal claims made against us

Special categories of data

Special categories of data are data relating to your:

• health
• sex life
• sexual orientation
• race
• ethnic origin
• political opinion
• religion
• trade union membership and
• genetic and biometric data.

We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:

• you have given explicit consent to the processing
• we must process the data in order to carry out our legal obligations
• we must process data for reasons of substantial public interest
• you have already made the data public.

We will use your special category data:

• anonymously, for the purposes of equal opportunities monitoring
• in assessment for reasonable adjustments for disabled employees.

We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

Criminal conviction data

We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment should you be successful in obtaining employment. We use criminal conviction data in the following ways:

• to aid us in making a decision regarding your suitability for employment

We rely on the lawful basis of it being a contractual requirement in line with the Rehabilitation of Offenders Act 1975 to process this data.

If you do not provide your data to us

One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not able to process, or continue with (as appropriate), your application.

Sharing your data

If you complete your application form online, your data will be processed by Talos360. A copy of their Privacy Statement is available here: https://talos360.co.uk/privacy-policy/

If you do not wish to complete your application form online you can email recruitment@ymcatrinity.org.uk requesting either a word document or paper copy for completion. No other format is available.

Once your application is received your data will be shared with colleagues within YMCA Trinity Group where it is necessary for them to undertake their duties with regard to recruitment. This includes, for example, the HR department, those in the department where the vacancy is who responsible for screening your application and interviewing you, the IT department where you require access to our systems to undertake any assessments requiring IT equipment.

In some cases, we will collect data about you from third parties, such as employment agencies.

Your data will be shared with third parties if you are successful in your job application. In these circumstances, we will share your data in order to

• obtain references as part of the recruitment process
• obtain a criminal records check
• set up a cloud based online personnel file
• set up online training

Copies of their Privacy Statements are available on request. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

Protecting your data

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

How long we keep your data for

In line with data protection principles, we only keep your data for as long as we need it for and this will depend on whether or not you are successful in obtaining employment with us.

If we have sought your consent to keep your data on file in order to contact you for future suitable job vacancies, and you have provided consent, it will be retained for 6 months once the recruitment exercise ends.

We will keep your data for 6 months once the recruitment exercise ends should any claims be brought against us. At the end of this period, we will securely delete or destroy your data, unless you have already withdraw your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.

If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy statement for employees, which will be provided to you.

Automated decision making

No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

Your rights in relation to your data

The law on data protection gives you certain rights in relation to the data we hold on you. These are:

• the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy statement
• the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
• the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
• the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
• the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
• the right to portability. You may transfer the data that we hold on you for your own purposes
• the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
• the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please contact Clare Reeves, 01733 373178.

Making a complaint

The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.