Privacy Notice for Job Applicants
In accordance with the General Data Protection Regulation (GDPR), PPV Group Ltd of Unit 7 Talon
Court, Yaxley, Peterborough, PE7 3FW has implemented this privacy notice to inform you, as
prospective employees of our Company, 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 organisation measures
g) we comply with the relevant GDPR procedures for international transferring of personal data
B) TYPES OF DATA HELD
Personal data is any information about an individual from which that person can be identified. It does not include anonymous data which does not identify the individual.
We collect, store and use several categories of personal data on our prospective employees in order to carry out effective and efficient processes. We keep this data in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example, recruitment logs. It is your responsibility to keep us up to date with any changes to your personal details so that we can make sure that your personal data is accurate. If your personal details change, you must notify the HR Team – hr@ppv.org.uk.
Specifically, we collect, store and use the following types of data:
a) personal details such as name, previous names, title, address, phone numbers, email address, date of birth;
b) name and contact details of your next of kin;
c) your photograph;
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 etc;
j) driving licence;
k) criminal convictions
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, former employers when gathering references or credit reference agencies.
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.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
| Activity requiring your data | Lawful basis |
|---|---|
| Carry out the employment contract that we have entered into with you e.g. using your name, contact details, education history, information on any disciplinary, grievance procedures involving you | Performance of the contract |
| Ensuring you are paid | Performance of the contract |
| Ensuring tax and National Insurance is paid | Legal obligation |
| 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 which are to recruit, retain and develop suitably qualified employees and ensure the effective operation of the business. |
| Making decisions about salary and other benefits | Our legitimate interests which are to administer fair and consistent remuneration and benefits arrangements and support workforce management. |
| Ensuring efficient administration of contractual benefits to you | Our legitimate interests which are to provide and manage employee benefits efficiently and accurately. |
| Enrolling you in our pension scheme and administering the scheme | Legal obligation |
| Effectively monitoring both your conduct, including timekeeping and attendance, and your performance and to undertake procedures where necessary | Our legitimate interests which are to maintain expected standards of performance and conduct, support employee development, and protect business operations. |
| Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained | Our legitimate interests which are to ensure effective workforce administration, business continuity, and employee welfare. |
| Implementing grievance procedures | Our legitimate interests which are to investigate and resolve workplace concerns fairly and maintain positive employee relations. |
| Assessing training needs | Our legitimate interests which are to identify and provide appropriate training and professional development opportunities and ensure employees have the skills required for their roles. |
| Implementing an effective sickness absence management system including monitoring the amount of leave and subsequent actions to be taken including the making of reasonable adjustments | Our legitimate interests which are to support employee wellbeing, manage attendance effectively, maintain operational resilience, and meet obligations relating to employee support. |
| Gaining expert medical opinion when making decisions about your fitness for work | Our legitimate interests which are to assess fitness for work, support employee health and wellbeing, and facilitate informed employment decisions. |
| Managing statutory leave and pay systems such as maternity leave and pay etc | Legal obligation |
| Business planning and restructuring exercises | Our legitimate interests which are to plan workforce requirements, improve operational efficiency, and support the long-term viability of the business. |
| Dealing with legal claims made against us | Our legitimate interests which are to establish, exercise or defend legal claims and protect the organisation's legal rights and interests. |
| Preventing fraud | Our legitimate interests which are to protect the organisation, employees, customers and other stakeholders from fraudulent activity and financial loss. |
| Ensuring our administrative and IT systems are secure and robust against unauthorised access | Our legitimate interests which are to maintain the confidentiality, integrity and availability of company systems and information assets and protect against cyber threats. |
| Providing employment references to prospective employers, when our name has been put forward by the employee/ex-employee, to assist with their effective recruitment decisions | Legitimate interest of the prospective employer and to support employees and former employees in obtaining future employment and assist prospective employers in making informed recruitment decisions. |
| Operating CCTV systems at company premises for security, health and safety, and incident investigation purposes | To protect employees, visitors, company property and confidential information; prevent and detect crime; investigate incidents; and maintain a safe working environment. |
| Using vehicle tracking and telematics systems in company vehicles | To ensure employee safety, protect company assets, optimise fleet management, verify working time where relevant, improve operational efficiency, investigate incidents, and comply with insurance obligations. |
| Conducting identity verification checks | Legitimate interests – to verify employees' identity, maintain site security, meet customer contractual requirements, and reduce the risk of fraud and unauthorised access to customer premises. |
| Obtaining and reviewing employment history covering the previous five years | Legitimate interests – to verify employment history and assess suitability for roles where customers require pre-employment screening. |
| Obtaining address history covering the previous five years | Legitimate interests – to support identity verification and security screening requirements imposed by customers. |
| Conducting sanctions screening checks | Legitimate interests – to protect the organisation and its customers from regulatory, financial, and reputational risks associated with engaging sanctioned individuals. |
| Carrying out DBS checks where required for the role or customer contractual requirements | Legitimate interests, together with compliance with the conditions for processing criminal offence data under Article 10 UK GDPR and Schedule 1 of the Data Protection Act 2018. |
| Sharing the outcome of screening checks with customers, where this is necessary to obtain approval for site access | Legitimate interests – to comply with contractual obligations to customers and enable decisions regarding access to customer premises. Individual consent is required. |
| Recording and processing timesheet information, including hours worked, overtime and assignments worked | Performance of contract – to calculate and administer pay and other contractual entitlements; Legal obligation – to comply with obligations under the Working Time Regulations 1998; Legitimate interests – to manage job costing, resource planning, customer billing, project management and the efficient operation of the business. |
| H&S personnel name | Legal obligation – To identify designated H&S personnel and meet workplace H&S requirements. |
| Work telephone number | Legal obligation – To allow H&S personnel to be contacted quickly. |
| Personal telephone number | Legal obligation – To allow the H&S personnel to be contacted where no work number is available. |
| Photograph/image | Legal obligation – To allow workers/visitors to quickly recognise the designated H&S personnel. |
| Company/work mobile added to operational work group. |
Legitimate Interests – We may use employees' and workers' contact details, including work or personal telephone numbers where appropriate, to facilitate workplace communications through approved group messaging platforms. These groups may be used to communicate operational information, site updates, health and safety information and other relevant workplace communications. Our lawful basis for this processing is Legitimate Interests (Article 6(1)(f) UK GDPR), namely our legitimate interest in maintaining effective and timely communication with our workforce. Where a personal telephone number is used within a group messaging service, the number may be visible to other members of the group. We will only use personal contact details in this way where it is necessary and proportionate for the intended business purpose and appropriate safeguards are in place. Legitimate Interests – To maintain quick communication throughout the business. |
| Personal mobile added to a work group. |
E) SPECIAL CATEGORIES OF DATA
Special categories of data are data 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 carry out processing activities using special category data:
a) for the purposes of equal opportunities monitoring
b) to determine reasonable adjustments
Most commonly, we will process special categories of data when the following applies:
a) you have given explicit consent to the processing
b) we must process the data in order to carry out our legal obligations
c) we must process data for reasons of substantial public interest
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.
G) 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. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of our legitimate interests under Article 6(1)(f) UK GDPR to process this data.
H) WHO WE SHARE YOUR DATA WITH
Employees within our company who have responsibility for recruitment, administration of payment and contractual benefits and the carrying out of performance related procedures 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.
We may share your personal data with carefully selected third-party service providers who process personal data on our behalf and under our instructions to support our employment and business operations. These include:
• Staffology for payroll administration and processing employee payments;
• EEBS for the administration and payment of subcontractors;
• BrightHR for personnel and human resources management;
• Royal London and St. James’s Place for the administration of workplace pension schemes and pension-related services;
• Experian to conduct right to work, identity verification and background screening checks where required for your role;
• Verizon for vehicle tracking and telematics services in relation to company vehicles;
• Thistle for the operation and management of CCTV systems to support security, health and safety, and incident investigation purposes.
• Crashplan for our IT system backup
We only share personal data that is necessary for these purposes and require all third parties to respect the security of your personal data and to process it in accordance with applicable data protection laws.
We may also share your data with third parties as part of a Company sale or restructure, or for other reasons 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 share your data with bodies outside of the European Economic Area. These countries included are:
• America
The reason for transferring data to these countries is that our IT backup servers are located there.We have put the following measures in place to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred process it in a way required by EU and UK data protection laws:
• The data is encrypted.
• IT maintains control over the encryption key.
• They maintain software, storage, network, hardware and security components.
• They perform rigorous quality testing of platform and product code and follow industry security best practices.
• They leverage strong authentication protocols to ensure authorised customer access.
• They conduct ongoing vulnerability testing by professional third parties and internal teams.
• They provide full-time monitoring of the cloud environment and maintain a dedicated response team.
• They maintain compliance certificates on their product and infrastructures to validate their secure programme. Additionally, they ensure and monitor appropriate security assurance obligations for SCO1, SCO2 AND ISO27001.
I) 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.
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 and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for six months once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for nine months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. 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) 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.
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 hr@ppv.org.uk
L) MAKING A COMPLAINT
If you consider your data rights have been breached, you can make a complaint to us at any time using any of the following methods:
• Email: The HR Director mark.reed@ppv.org.uk or hr@ppv.org.uk
• In person: To the HR Director
More information is available in our separate policy on Data Protection Complaints; a copy is attached to this privacy notice.
You can also raise a complaint with the Information Commissioner (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.
M) DATA PROTECTION COMPLIANCE
Our Data Protection Officer is:
Mark Reed
Mark.reed@ppv.org.uk
Our appointed compliance officer in respect of our data protection activities is:
Rebecca Larrington
Rebecca@ppv.org.uk
Mark Reed
Operations Director