TIRO Training Ltd is aware of its obligations under the General Data Protection Regulation (the “UK GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with the Data Protection Legislation, the types of data that we collect and hold on you as an applicant. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
Data controller details
Data protection principles
In relation to your personal data, we will:
- process it fairly, lawfully and in a clear, transparent way
- collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
- only use it in the way that we have told you about
- ensure it is correct and up to date
- keep your data for only as long as we need it
- process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed
Types of data we process
We process many types of data about you, including:
- your personal details including your name, address, date of birth, email address, phone numbers.
- information included on your CV including references, education history and employment history.
- your biometric data as part of the recruitment process to comply with rights to work checks.
- Salary expectations, reasons for leaving previous role.
- Information for the purpose of completing background checks as part of our on-boarding process, including seeking references from previous employers.
- Information about directorships you hold.
- Information about your race or national or ethnic origin, to ensure meaningful equal opportunity morning and reporting.
How we collect your data
We collect data about you in a variety of ways including the information you would normally include in a CV. Further information will be collected directly from you when you complete forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence.
In some cases, we will collect data about you from third parties, such as recruitment agencies, former employers when gathering references or credit reference agencies, or the disclosure and barring service. Personal data is kept in secure in our cloud-based HR systems.
Why we process your data
The law on data protection allows us to process your data for certain reasons only:
- in order to perform the employment contract that we are party to
- in order to carry out legally required duties
- for us to carry out our legitimate interests
- where it is needed in the public interest or for official purposes for example, this may involve assisting with a police investigation.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
We need to collect your data to ensure we are complying with legal requirements such as:
- carrying out checks in relation to your right to work in the UK and
- making reasonable adjustments for disabled applicants.
We also collect data so that we can carry out activities which are in the legitimate interests of TIRO. We have set these out below:
- making decisions about who to offer employment to
- making decisions about salary and other benefits
- dealing with legal claims made against us
If you are unsuccessful in obtaining employment, we will seek your consent to retaining your data in case other suitable job vacancies arise within TIRO for which we think you may wish to apply. You are free to withhold your consent to this and there will be no consequences for withholding consent.
Why we process ‘special category’ data
“Special category data” is more sensitive personal information that requires higher levels of protection. We need further justification for collecting, storing, and using this type of personal information. We may process special categories of personal information in the following circumstances:
- in limited circumstances, with your explicit consent.
- Where it is needed to assess your working capacity on health grounds, subject to appreciate confidentiality safeguards.
- Where it is necessary for establishing, exercising, or defending legal claims.
- Where it is needed in the public interest, such as for equal opportunities monitoring.
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. For example, to ensure we provide you with a safe place of work or to consider making reasonable adjustments. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not able to process, or continue with (as appropriate), your application.
Sharing your data
Your data will be shared with recruiting managers within TIRO where it is necessary for them to undertake their duties about recruitment.
“Third parties” includes third-party service providers (including contractors, designated agents, our software providers, and external consultants) and the joint venture entities. It also includes individuals from affiliated organisations in the industry who may be involved in the interview process.
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Transferring your data outside of the UK
Your personal data is stored in a range of different places, including on your application record, in the application management systems and in other IT systems (including our email system). We may store some or all your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
- We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
- We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.
Protecting your data
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal information to those staff, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Lead.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for, and this will depend on whether you are successful in obtaining employment with us. 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 6 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 1 year once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdraw your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
If your application is successful, your data will be kept and transferred to the systems we administer for staff. We have a separate privacy notice for staff, which will be provided to you.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
- the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
- the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
- the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
- the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
- the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- the right to portability. You may transfer the data that we hold on you for your own purposes
- the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
- the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent 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 the Data Protection Lead, see contact details below.
Making a complaint
The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO. You can contact the Information Commissioner’s Office (ICO) on 0303 123 1113 or via their website.
How do I contact you?
If you’re worried about how we get and use your information, you can speak to our Data Protection Lead at TIRO, who will be able to help you and answer any queries you have. You can email at email@example.com
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
This Privacy Notice was last updated on 03rd November 2023
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