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Candidate Privacy Notice
What is the purpose of this notice?
MDS Global Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. This notice makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulations and Data Protection Act 2018.
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- Relevant to the purposes we have told you about and limited only to those purposes
- Accurate and kept up to date
- Kept only as long as necessary for the purposes we have told you about
- Kept securely
The kind of information we hold about you
In connection with your application to work with us, we will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter
- The information you have provided in our online application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications and interests, salary information, health conditions and reference details.
- Any information you provide to us during an interview or as part of the recruitment process
- Any information that we collect during the recruitment process such as assessment materials, test results and personality profiles
- Any information we collect that we are legally required to do so, for example to prove your right to work
- Any information that we request to provide proof of your identity such as utility bill
- Information relating to your driving licence
- We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about your health, including any medical condition, health and sickness record
- Information about criminal convictions and offences
- Any information regarding your appearance and behaviour captured on CCTV if you attend our work premises for interview.
How is your personal information collected?
We collect personal information about candidates from the following sources:
- You, the candidate
- We currently use the following recruitment agencies which are part of our preferred supplier list: Circle, Frazer John, Robert Walters, PB Recruitment, FRS Limerick, Morson Group and RPI International. In addition to these 3rd parties, where we have a niche or hard to fill vacancy we will engage with other providers and have therefore also engaged with the following in the last 12 months due to their specialism in certain markets: Adele Carr, Search and Proactive. We also use Job Site UK, Linked IN, Indeed, Totaljobs, Technojobs and Glassdoor as job boards.
- Your named referees, from whom we collect the following categories of data:
- Previous role held
- Reason for leaving
- Dates of employment
- Sickness/absence information
- Reference of character and integrity and whether your previous employer would re-employ
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 work or 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 determine a candidate’s suitability for a role to ensure that as a business we can appoint successfully any vacancies that we have.
Therefore, the lawful basis we rely on for processing your personal data is article 6(1)(f) of the UK GDPR.
If you provide us with any information about reasonable adjustments, you require under the Equality Act 2010 the lawful basis we rely on for processing this information is article 6(1)(c) to comply with our legal obligations under the Act.
The legal basis we rely on to process any information you provide as part of your application which is special category data, such as health, religious or ethnic information is article 9(2)(b) of the UK GDPR, which also relates to our obligations in employment and the safeguarding of your fundamental rights and article 9(2)(h) for assessing your work capacity as an employee. And Schedule 1 part 1(1) and (2)(a) and (b) of the DPA2018 which relates to processing for employment, the assessment of your working capacity and preventative or occupational medicine.
As part of our recruitment process, your information relating to your application (including CV and covering letter, online application form, any associated tests/personality questionnaire and assessment notes, references) will be shared internally with the appropriate Hiring Manager/s as well as other individuals involved directly within the recruitment process such as the HRD department.
We also need to process your personal information to decide whether to enter into a contract of employment with you.
Having received your CV and covering letter OR your online application form, we will then 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 suitable to invite you for an interview. If we decide to invite you to an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. In addition to interview, as part of the recruitment process, we may also ask you to complete technical assessments or personality profiles to determine your suitability. If we decide to offer you the role, we will then take up references before confirming your appointment.
Processing your information outside of the UK
In 2019 MDS Global Ltd became a subsidiary of Volaris Group in Canada and as a result of the acquisition, and changes to the recruitment process, any candidate application information is uploaded to the Volaris HR system (WorkDay). Information is stored on servers in Canada and is accessible only to restricted authorised personnel in MDS Global, Lumine and Volaris in the UK and Canada. The transfer of personal data to a country outside of the UK and EEA may take place only if the third country in question ensures an adequate level of protection. Canada is considered as providing an adequate level of protection for personal data transferred or shared from the UK/EEA to recipients subject to the Personal Information Protection and Electronic Documents Act. In addition, other controls such as the use of Standard Contractual Clauses are in place.
If you fail to provide personal information
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.
How we use particularly sensitive personal information
- We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview or your employment.
- To provide proof of your right to work status which we are legally obliged to collect
Information about criminal convictions
We may collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We may carry out a criminal record check to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application:
- Workday – Our HR system/Applicant Tracking system
- Circle Group, Robert Walters, Frazer John, Morson Group, RPI International, PBRecruitment, FRS – Our preferred recruitment agencies. These suppliers will collect the information as mentioned above in our application form together with your curriculum vitae and covering letter which is used to assess your suitability for the role. From time to time we may also need to engage with other agencies.
- Giant Screening – Our Criminal Records Check supplier
- Mettl – Skills testing supplier
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Data Privacy Officer by contacting DPO@mdsglobal.com
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.
How long will you use my information for?
Should you be unsuccessful in your application, or you decide not to commence employment with us, we will retain your personal information for a period of six months after we have communicated to you our decision. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.
Workday (our HR/recruitment system) will provide us with management information about our recruitment campaigns – this is anonymised information which will tell us how effective our campaign has been. Information relating to your application will be retained within the Workday system for a period of 12 months from the date that you applied.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
Should you be successful in your application and we offer a role to you, your personal information will be placed on your employee personnel record and this will be retained in line with our employee data retention policy.
Rights of access, correction, erasure, and restriction
Under certain circumstances, you have rights in connection with personal information and by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer at MDS Global, Suite 423, Chadwick House, Birchwood Park, Warrington WA3 6AE, in writing or by email at DPO@mdsglobal.com.
Right to withdraw consent
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the Data Protection Officer at the contact details above. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
Data protection officer
We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact our DPO, Kate Whittaker at the above contact address. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.