Data Protection Privacy Notice

Job Applicants

Introduction

As part of any recruitment process, we collect and process personal information relating to job applicants.

We are committed to being transparent about how we handle personal information, to protecting the privacy and security of personal information and to meeting our data protection obligations under the Data Protection (Jersey) Law 2018.

The purpose of this privacy notice is to make job applicants aware of how and why we collect and use their personal information during the recruitment process.

This privacy notice applies to all job applicants, whether they apply for a role directly or indirectly through an employment agency.

If you have any questions about this privacy notice or about how we handle your personal information, please contact Paul Byrne, the Digital Jersey Data Protection Manager (DPM), at DPM- DJ@propelfwd.com

What types of personal information do we collect about you?

We collect, use and process a range of personal information about you during the recruitment process. This includes (as applicable):

your contact details, such as your name, address, telephone number and email address
personal information provided by you in a CV, any application form, cover letter or interview
reference
information about your right to work in Jersey
copies of qualification certificates
other background check documentation
details of your skills, education, qualifications, experience and/or work history with previous employers
information about your current salary level, including benefits and pension entitlements
your professional memberships

We may also collect, use and process the following special category information during the recruitment process (as applicable):

whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process
information about your age, nationality, race, sex and/or sexual orientation
information about criminal convictions and/or offences.

How do we collect your personal information?

We collect personal information about you during the recruitment process either directly from you or sometimes from a third party such as an employment agency. We may also collect personal information from other external third parties, such as references from current and former employers, information from background check providers and criminal record checks from the Disclosure and Barring Service (DBS) where applicable. Other than employment agencies, we will only seek personal information from third parties during the recruitment process once an offer of employment has been made to you and we will inform you that we are doing so.

Your personal information may be stored in different places, including on your application record, in our HR management system and in other IT systems, such as the e-mail system.

We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software), to assist with our recruitment process. We use Pinpoint to process personal information as a data processor on our behalf. Pinpoint is only entitled to process your personal data in accordance with our instructions.

The data that we collect from you and process using Pinpoint’s Services will be transferred to and stored at one of several datacentre locations in Amsterdam (Netherlands) and may be synchronised to one of several datacentre locations in London (United Kingdom) for backup and redundancy purposes. By submitting your personal data, you agree to this transfer, storing or processing.

Why do we use your personal information?

The collection and processing of your personal data throughout the recruitment process will be necessary primarily to enable us to take steps at your request to enter into a contract with you and to enable us to comply with our legal obligations where such obligation exists.

The purposes for which we are processing, or will process, your personal information are to:

manage the recruitment process and assess your suitability for employment
decide to whom to offer a job
comply with statutory and/or regulatory requirements and obligations, e.g. checking your right
to work in Jersey
comply with the duty to make reasonable adjustments for disabled job applicants
ensure effective HR, personnel management and business administration
enable us to establish, exercise or defend possible legal claims

What if you fail to provide personal information?

If you fail to provide certain personal information when requested, we may not be able to process your job application properly or at all, we may not be able to enter into a contract with you, or we may be prevented from complying with our legal obligations.

Who has access to your personal information?

Your personal information may be shared internally within Digital Jersey for the purposes of the recruitment exercise, including with managers in the department which has the vacancy, and externally with professional HR advisers.

We may also use service providers acting as data processors on the Company’s behalf for the purposes of shortlisting, verification and/or background or police checks. These service providers may be located outside the Channel Islands.

We may sometimes be required to disclose your information to external third parties such as to local employment authorities, insurance companies, courts and tribunals, or regulatory bodies and/or law enforcement agencies for the purpose of complying with applicable laws and regulations, or in response to legal process.

How do we protect your personal information?

We have put in place measures to protect the security of your personal information. We have internal policies, procedures and controls in place to try and prevent your personal information from being accidentally lost or destroyed, altered, disclosed or used or accessed in an unauthorised way. In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know in order to perform their job duties and responsibilities.

Where your personal information is shared with third parties, we require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with data protection law. We only allow them to process your personal information for specified purposes and in accordance with its instructions and we do not allow them to use your personal information for their own purposes.

Digital Jersey use Microsoft Teams and have a dedicated HR folder with limited access controls to protect your information from unauthorised disclosure. When we share your information outside of the Teams system, the link used is set for that specific person and cannot be further shared, downloaded, or printed.

We also have in place procedures to deal with a suspected data security breach, and we will notify the Jersey Office of the Information Commissioner (or any other applicable supervisory authority or regulator) and you of a suspected breach where we are legally required to do so.

For how long do we keep your personal information?

We will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed.

If your application for employment is unsuccessful, we will generally hold your personal information for six months after the end of the relevant recruitment exercise. If you have consented to us keeping your personal information on file in case there are future suitable employment opportunities with us, we will hold your personal information for a further six months after the end of the relevant recruitment exercise, or until you withdraw your consent, if earlier.

If your application for employment is successful, personal information gathered during the recruitment process will be retained for the duration of your employment and in accordance with the privacy notice for employees.

Personal information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our IT systems and we will also require third parties to destroy or erase such personal information where applicable.

Your rights in connection with your personal information

As a ‘data subject’, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:

request access to your personal information
request rectification of your personal information
request the erasure of your personal information
restrict the processing of your personal information
object to the processing of your personal information
request the transfer of your personal information to another party
object to automated decision-making

If you wish to exercise any of these rights, please contact our DPM, at DPM-DJ@propelfwd.com We may need to request specific information from you in order to verify your identity and check your right to access the personal information or to exercise any of your other rights. This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you have provided your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This will not, however, affect the lawfulness of processing based on your consent before its withdrawal. If you wish to withdraw your consent, please contact our DPM, at DPM-DJ@propelfwd.com

If you believe that we have not complied with your data protection rights, you have the right to make a complaint to the Jersey Office of the Information Commissioner.

Automated decision making

Automated decision making occurs when an electronic system uses your personal information to make a decision without human intervention. We do not envisage that any recruitment decisions will be taken about you based solely on automated decision-making, including profiling.

Changes to this privacy notice

We reserve the right to update or amend this privacy notice at any time.

Contact

If you have any questions about this privacy notice or how we handle your personal information, please contact our Data Protection Manager, at DPM-DJl@propelfwd.com