Job Applicant Privacy Notice
Data Controller: For information, contact firstname.lastname@example.org
Data protection officer: Contact Markus Kubeck, Crestbridge Limited, 47 Esplanade, St. Helier, Jersey JE1 0BD, Channel Islands, Great Britain. Email: email@example.com
As part of any recruitment process, Crestbridge collects and processes personal data relating to job applicants. Crestbridge is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does Crestbridge collect?
Crestbridge collects 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, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- whether or not you have a disability for which Crestbridge needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the jurisdiction for which you are applying to work; and
Crestbridge collects this information in a variety of ways. For example, data might be contained in CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment
Crestbridge will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. Crestbridge will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does Crestbridge process personal data?
Crestbridge needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, Crestbridge needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in Jersey, UK, Bahrain, Luxembourg and the Cayman Islands before employment starts.
Crestbridge 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 Crestbridge to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. Crestbridge may also need to process data from job applicants to respond to and defend against legal claims.
Where Crestbridge relies on legitimate interests as a lawful basis for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
Crestbridge processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
For some roles, Crestbridge is obliged to seek information about criminal convictions and offences. Where Crestbridge seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
Crestbridge will not use your data for any purpose other than the recruitment exercise for which you have applied.
If your application is unsuccessful, Crestbridge will keep your personal data on file in case there are future employment opportunities for which you may be suited. Crestbridge will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
Who has access to 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, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
Crestbridge will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Crestbridge will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure Scotland Service to obtain necessary criminal records checks.
Your data may be transferred outside the European Economic Area (EEA) if you are applying to work in Bahrain or the Cayman Islands. Data is transferred outside the EEA on the basis of your application and for the purposes of sharing your CV or resume with hiring managers locally.
How does Crestbridge protect data?
Crestbridge takes the security of your data seriously. It has 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 our employees in the proper performance of their duties.
For how long does Crestbridge keep data?
If your application for employment is unsuccessful, Crestbridge will hold your data on file for 6 months after the end of the relevant recruitment process. At the end of this 6-month period, we will ask you separately if you would like your details retained by us so that you may be considered for potential opportunities. At the end of that period (or once you withdraw your consent), your data will be deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require Crestbridge to change incorrect or incomplete data;
- require Crestbridge 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 Crestbridge is relying on its legitimate interests as the legal ground for processing; and
- ask Crestbridge to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override Crestbridge's legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact our Data Protection Officer who will provide a Data Subject Request form and provide details of information required from you in order to process your request.
If you believe that Crestbridge has not complied with your data protection rights, you can complain to the relevant Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to Crestbridge during the recruitment process. However, if you do not provide the information, Crestbridge may not be able to process your application properly or at all.