Privacy Notice for Job Applicants
In accordance with the General Data Protection Regulation (GDPR), we have implemented this privacy notice to inform you, as prospective employees of Jack Badger, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for, and your rights regarding your data.
A- Data Protection Principles
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
a - processing is fair, lawful, and transparent
b - data is collected for specific, explicit, and legitimate purposes
c - data collected is adequate, relevant, and limited to what is necessary for the purposes of processing
d - data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
e - data is not kept for longer than is necessary for its given purpose
f - data is processed in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing, accidental loss, destruction, or damage by using appropriate technical or organisational measures
g - we comply with the relevant GDPR procedures for international transferring of personal data, although we do not currently share your data with bodies outside the European Economic Area (EEA), as outlined in Section H.
B - Types of data held
We keep several categories of personal data on our prospective employees, as relevant to the role applied for, to carry out effective and efficient recruitment processes. We keep this data in recruitment files relating to each vacancy and within our secure computer systems, such as recruitment logs.
Specifically, we hold the following types of data:
a - personal details such as name, address, phone numbers
b - name and contact details of your next of kin (if relevant for emergency contact or specific role requirements)
c -your photograph (if provided for identification or application purposes)
d - your gender, marital status, information of any disability you have, or other medical information
e - right to work documentation
f - information on your race and religion for equality monitoring purposes
g - information gathered via the recruitment process, such as that entered into a CV or included in a CV cover letter
h - references from former employers
i - details on your education and employment history
j - driving licence
k - criminal convictions (where relevant to the role and permitted by law, as outlined in Section G).
C - Collecting your data
You provide several pieces of data to us directly during the recruitment exercise.
In some cases, we will collect data about you from third parties, such as employment agencies or former employers when gathering references. For specific roles, we may also collect data from background check providers where relevant and legally permitted. We only collect data necessary for the recruitment process.
Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins.
D - Lawful basis for processing
The law on data protection allows us to process your data for certain reasons only, as outlined below. For special category data, additional lawful bases apply, as described in Section E.
Activities requiring your data and the lawful basis why:
- Carrying out checks in relation to your right to work in the UK - Legal obligation.
- Making reasonable adjustments for disabled employees - Legal obligation.
- Making recruitment decisions in relation to both initial and subsequent employment (e.g., promotion) - Our legitimate interests in selecting suitable candidates for employment.
- Making decisions about salary and other benefits - Our legitimate interests in ensuring fair and competitive compensation.
- Making decisions about contractual benefits to provide to you - Our legitimate interests in ensuring fair and competitive compensation.
- Assessing training needs - Our legitimate interests in developing candidate skills for the role.
- Dealing with legal claims made against us - Our legitimate interests in defending our organisation.
- Preventing fraud - Our legitimate interests in ensuring the integrity of the recruitment process.
E - Special categories of data
Special categories of data include information relating to your:
a - health
b - sex life
c - sexual orientation
d - race
e - ethnic origin
f - political opinion
g - religion
h - trade union membership
i - genetic and biometric data.
We process such data only where necessary and lawful, primarily for the following purposes:
a - for equal opportunities monitoring (typically anonymised to protect your privacy)
b - to determine reasonable adjustments for disabilities or health conditions.
Most commonly, we will process special categories of data when:
a - we must process the data to carry out our legal obligations (e.g., making reasonable adjustments for disabilities)
b - we must process data for reasons of substantial public interest (e.g., equal opportunities monitoring)
c - you have given explicit consent to the processing (where no other lawful basis applies)
d - you have already made the data public.
F - Failure to provide data
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment or administer contractual benefits. However, we will assess each case individually to determine if alternative arrangements can be made.
G - Criminal conviction data
We will only collect criminal conviction data where it is appropriate given the nature of your role and where permitted by law (e.g., under the Data Protection Act 2018 for roles requiring background checks). This data will usually be collected at the recruitment stage or during your employment to determine your suitability or continued suitability for the role. We rely on the lawful basis of legitimate interests, in accordance with applicable UK law, to process this data.
H - Who we share your data with
Employees within our company who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processed in line with GDPR.
Data is shared with third parties only where necessary for the following purposes:
a - To conduct background checks, verify qualifications, or manage applications through trusted third-party providers, such as background check agencies or recruitment platforms.
b - To utilise third-party tools, such as applicant tracking systems or skills assessment platforms, to streamline the recruitment process.
c - To engage professional services, such as legal or consultancy firms, to ensure compliance with recruitment regulations or support hiring decisions.
We may also share your data with third parties as part of a company sale, restructure, or to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We do not share your data with bodies outside of the European Economic Area.
I - Protecting your data
We are committed to protecting your data against accidental loss, disclosure, destruction, or abuse. We have implemented appropriate technical and organisational measures, such as secure data storage, access controls, and encryption, to safeguard your personal data.
J - Retention periods
We only keep your data for as long as we need it for, which, in relation to unsuccessful candidates, is six months to a year.
If your application is not successful, we may seek your consent to retain your data for future suitable job vacancies. If you provide consent, we will keep your data for nine months after the recruitment exercise ends. If consent is not provided or is withdrawn, we will retain your data for six months. At the end of these periods, your data will be securely deleted or destroyed using appropriate technical measures.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time by contacting our data protection compliance officer (see Section N). This means that we will stop processing your data and there will be no consequences of withdrawing 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 notice for employees, which will be provided to you.
K - Automated decision making
Automated decision-making means making decisions about you using no human involvement, e.g., using computerised filtering equipment. 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.
L - Your rights
You have the following rights in relation to the personal data we hold on you:
a) the right to be informed about the data we hold on you and what we do with it
b) the right of access to the data we hold on you. We operate a separate Subject Access Request policy and all such requests will be dealt with accordingly
c) the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’
d) the right to have data deleted in certain circumstances. This is also known as ‘erasure’
e) the right to restrict the processing of the data
f) the right to transfer the data we hold on you to another party. This is also known as ‘portability’
g) the right to object to the inclusion of any information
h) the right to regulate any automated decision-making and profiling of personal data.
To exercise any of the rights listed above, please contact our data protection compliance officer (see Section N). We will respond to your request within one month, as required by GDPR, unless the request is complex, in which case we will inform you of any extension.
In addition to the above rights, you also have the unrestricted right to withdraw consent, that you have previously provided, to our processing of your data 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 Cat Upton on the details below.
M - Making a complaint
If you think your data rights have been breached, we encourage you to contact our data protection compliance officer (see Section N) to resolve the issue. You also have the right to raise a complaint with the Information Commissioner’s Office (ICO). You can contact the ICO at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
N - Data protection compliance
Our appointed compliance officer in respect of our data protection activities is:
Cat Upton
Email: cat@jackbadger.co.uk
Phone: 01457 854440
Address: Hawkshead, Hope Street, Glossop, SK13 7SS
