This policy is currently under review
1. POLICY STATEMENT
This policy is designed to provide information on how we deal with the privacy of job applicants who apply any member of the Innovation Group for a job and the personal data we hold about them during the recruitment process. For a full list of our group companies see the appendix (which we update from time to time).
To provide you with details of what information we may collect about you and to give you confidence in how we will use this information both internally and externally; and
To comply with legal requirements including privacy laws.
3. THE LEGISLATION
The General Data Protection Regulation 2016 (“GDPR”) regulates the way in which “personal data” (i.e. information about you) is processed.
For ease of reference in this policy, the GDPR, along with other relevant data privacy legislation, will be referred to collectively as “Data Protection Legislation”.
4. ABOUT THIS DOCUMENT
Innovation Group (referred to as “we”, “us”, “our”) takes your privacy seriously. We are fully committed to protecting your personal data. We will process and collect personal data and special categories of personal data about you. We recognise:
We will only process your personal data and special categories of personal data in accordance with Data Protection Legislation and we will adhere to the principles (as applicable) contained in the Data Protection Legislation.
The purpose of this policy is to provide you with information regarding the types of personal data and special categories of personal data that we hold and process about you and why.
Processing includes collecting, viewing, transferring, using, holding, storing, recording and destroying your personal data and special categories of personal data.
This policy is subject to change and any change to this policy or the appendix will be notified under Revision History.
5. WHAT DO ‘PERSONAL DATA’ AND SPECIAL CATEGORIES OF PERSONAL DATA’ MEAN?
‘Personal data” under the GDPR includes information relating to a living person, who can be identified directly or indirectly by such information (e.g. name, ID number, location data, an online identifier, one or more factors specific to the physical, physiological, genetic, mental, economic or social identity of that person).
“Special categories of personal data” under the GDPR relates to personal information about you of a more private nature and means genetic data, biometric data, data concerning a person’s sex life or orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and health.
The personal data and special categories of personal data about you held and processed by us may be held in manual or automated/electronic filing systems.
6. WHAT DO WE DO WITH YOUR PERSONAL DATA AND ON WHAT LEGAL BASIS?
We use the personal data you provide to us to process your job application. The legal grounds for processing can be summarised as follows:
To comply with our legal obligations. This includes the following information:
To pursue our legitimate interests as a business. This includes the following information:
Where you have consented for us to do so. This includes:
7. WHAT DO WE DO WITH YOUR SPECIAL CATEGORIES OF PERSONAL DATA AND ON WHAT LEGAL BASIS?
We process your special categories of personal data for different reasons. These are summarised below.
To enable you and us to perform our respective obligations or exercise out respective rights in respect of employment and social security and social protection law. This includes the following:
To establish, defend or exercise legal claims in an employment tribunal or any other court of law.
8. DISCLOSURE AND BARRING SERVICE (DBS CHECKS)
We may process personal data to carry out DBS checks (including criminal convictions):
9. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL DATA
We may share your personal data internally for the purposes set out above to HR employees involved in the recruitment process and/or line managers in the business who are involved in the recruitment process for the job role(s) you are applying.
We may share your personal data and special categories of personal data with other companies within Innovation Group. They may use your personal data for making decisions relating to recruitment.
We may share your personal data and special categories of personal data with third parties, agents, subcontractors and other organisations, as listed below, for the purposes of providing services to us or directly to you on our behalf:
We may share your personal data with the following in order to comply with our legal obligations:
When we use third party suppliers or providers, we only disclose to them any personal information that is necessary for them to provide their service. We have a contract in place that requires them to keep you information secure and not to use it other than in accordance with our specific instructions.
10. RECEIVING YOUR PERSONAL DATA
11. AUTOMATED DECISION MAKING AND PROFILING
We do not currently make decisions about you using automated means. We will notify you in writing if this position changes.
12. WHERE DO WE STORE YOUR PERSONAL DATA OR SPECIAL CATEGORIES OF PERSONAL DATA?
Your personal data and special categories of personal data is stored electronically on our secure servers which are located within the European Economic Area (“EEA”). Your personal data and special categories of personal data may also be stored in hard copy form and if so, it will be kept in access-restricted, locked filing cabinets.
We may transfer the personal data we collect about you to the South African branch of our Group Company (“IGBS”), responsible for our recruitment process.
There is not an adequacy decision by the European Commission in respect of South Africa. This means that South Africa is not deemed to provide an adequate level of protection for your personal data.
However, to ensure that your personal data does receive an adequate level of protection we have put in place appropriate measures to ensure that your personal data is treated by IGBS in a way that is consistent with and which respects Data Protection Legislation including imposing contractual obligations on IGBS.
13. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We keep your personal data and special categories of personal data for as long as is necessary to fulfil our legal obligations.
If you are unsuccessful in your application for a job with us, your personal data will be be destroyed in accordance with the retention policy for unsuccessful applicants under which we will destroy your personal data no later than 6 months after determination that your application has been unsuccessful, unless you consent to a longer period.
14. YOUR DUTIES
Please ensure that the information that we hold about you is accurate and up to date by keeping us informed of any changes to your personal data by emailing firstname.lastname@example.org.
15. YOUR RIGHTS
Under Data Protection Legislation, you have certain rights as a “data subject”.
You may make a formal request for access to personal data and/or special categories of personal data that we hold about you at any time. This is known as a Subject Access Request (“SAR”). A SAR can be made orally or in writing and we must respond within one month.
You also have other rights under Data Protection Legislation including:
Where we intend to process your personal data for a purpose other than as set out in this policy, we will provide you with information about the purpose prior to processing your personal data.
The way we process your personal data and the legal basis on which we rely to process it may affect the extent to which these rights apply. If you would like to exercise any of these rights, please address them in writing to email@example.com.
If you have any questions about any matter relating to data protection or the personal data and/or special categories of personal data that we process about you, please contact the DPO and firstname.lastname@example.org or write to us at Group Legal, Yarmouth House, 1300 Parkway, Solent Business Park, Whiteley, Hampshire, PO15 7AE.
Innovation Group employing entities (UK)
Innovation Fleet Services Limited
Innovation Property (UK) Limited
Motorcare Services Limited
The Innovation Group (EMEA) Limited