What information do we collect?
We collect 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, training, experience, professional memberships and employment history.
- Information about your current level of remuneration, including benefit entitlements.
- Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process.
- Information about your entitlement to work in the UK, including your National Insurance Number and/or Passport.
- Your comments relating to your suitability for the role and your personal interests.
Further personal data will be collected through interviews or other forms of assessment.
If successful, we also ask you to provide the contact details of two referees whom we will contact to obtain references for you. We assume that you have obtained their consent to give their details to us.
We collect this information by asking you to complete and submit a company starter form which will be sent to you with offer of employment paperwork.
Application data will be stored in a range of different places, as appropriate, including on our HR management systems and on other IT systems (including email).
Why does CML process personal data?
We need to process data to take steps at your request prior to entering into an employment contract with you. We may also need to process your data to enter into a contract with you. In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, it is mandatory to check a successful applicant's eligibility to work in the UK before employment starts. CML 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 us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job.
We will collect information about whether or not applicants are disabled so that we can make reasonable adjustments for candidates who have a disability. We process such information to carry out our legal obligations and exercise specific rights in relation to employment.
Who has access to your personal 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 and managers in the business area with a vacancy.
With the exception of your nominated referees for references, we will not share your data with third parties, unless we make you a conditional offer of employment. We will then share your data with certain third parties in order to comply with our legal obligations. These legal obligations include contacting former employers to obtain references for you if not completed beforehand and any employment background check providers to obtain necessary background checks. Successful candidates will also be asked to complete a confidential medical questionnaire, which will be sent by the candidate directly to CML’s Occupational Health Service (Aviva Occupational Health & Wellbeing) for assessment. Information about a disability or medical condition will only be reported to us in general terms of the candidate's ability to perform the job. This will allow any health and safety risk to be assessed and reasonable adjustment considered. The candidate’s permission will be sought by Aviva Occupational Health & Wellbeing before sharing any other medical information with us.
How does CML protect data?
We take the security of your data seriously. We have 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 those employees who require access to it in the proper performance of their duties.
For how long does CML keep data?
If your application is unsuccessful, your personal data will be kept for six months after the end of the relevant recruitment stage, after which it will be automatically destroyed. You may ask us to keep your personal data for longer, for example so that you receive alerts in relation to future employment opportunities for which you may be suited and do not have to duplicate information previously submitted for another role. You are free to ask us to delete your data at any time.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your Personnel File (electronic and paper based) and retained during your employment with CML. The periods for which your data will be held, together with further information about how CML collects and uses your personal information, will be provided to you in a staff privacy notice.
As a data subject, you have a number of rights. You can:
- Access and obtain a copy of your data on request.
- Require us to change incorrect or incomplete data.
- Require us 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 CML is relying on its legitimate interests as the legal ground for processing.
If you would like to exercise any of these rights, or have any questions about this policy or the information we hold about you, please contact [email protected]
If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner’s Office.
What if you do not want to provide personal data?
You are under no obligation to provide personal data to CML during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.