Effective Date: May 25, 2018
What is the purpose of this document?
This policy outlines how Four Seasons Health Care (“FSHC”) uses and protects any personal information about you during the recruitment and recruitment enquiries process.
This privacy notice is issued by FSHC (company number 05165301), with its registered office at Four Seasons Health Care, Norcliffe House, Station Road, Wilmslow, Cheshire, SK9 1BU, so when we refer to “we”, “us” or “our” in this privacy notice, we are referring to the FSHC as the data controller (those responsible for processing your data).
As a data controller, we are responsible for deciding how we hold and use personal information about you. You are reading this privacy notice because you are applying for work with us (whether as an employee, apprentice, worker or contractor) or because you have registered to be part of our Talent Network. It makes you aware of how and why your personal data will be used and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our Data Protection Officer (DPO) using the details below:
Data Protection Officer: firstname.lastname@example.org
Lingfield House, Lingfield Point, Darlington, DL1 1RW
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the supervisory authority for data protection issues in the UK (phone: 0303 123 1113 or at www.ico.org.uk/concerns . However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance.
Changes to this Privacy Notice and Changes to Your Details
We will need to update this privacy notice from time to time as the law and/or our business changes and develops. We will endeavour to tell you in advance by sending a service message to you if we hold your email address. Otherwise, please look out for information on our websites and materials that indicates we have changed this privacy notice.
If you continue to use our websites and/or services after we have changed our privacy notice, we will take this as an indication that you accept the changes.
It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
The kind of information we hold about you
In connection with your registration on our Talent Network or your application for work with us, we will collect, store, and use the following categories of personal information about you
• the information that you supplied when you registered on our Talent Network;
• the information you have provided to us in your curriculum vitae or covering letter;
• the information you have provided on our application form or via any application process, including name, title, address, telephone number, email address, date of birth, employment history and qualifications;
• notes of any information you provide to us during an interview; and
• results of any tests or assessments that you undertake as part of your application for work with us
How your personal information is collected
We collect personal information about candidates from the following sources:
• you, the candidate;
• online hiring providers, such as Career Builder UK Limited and Evolve Assess;
• certain recruitment agencies and apprenticeship service providers with whom we have relationships;
• agencies such as the Disclosure and Barring Service / P.V.G. etc in respect of criminal convictions; and
• your named referees, from whom we collect personal data contained within any reference that they provide us.
How we will use information about you
We will use the personal information we collect about you to:
• notify you of opportunities that appear to match your stated preferences;
• assess your skills, qualifications, and suitability for the role;
• carry out background and reference checks, where applicable;
• communicate with you about the recruitment process;
• keep records related to our hiring processes; and
• comply with legal or regulatory requirements.
Having received your CV and/or covering letter and/or your application and the results from any test that you take as part of the application process, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we may then take up references, carry out a criminal record and/or carry out any other kind of check that we consider necessary before confirming your appointment.
If successful and employed by us, to ensure your induction is as effective as possible, FSHC may, where applicable use your personal email address to send you your account log-in details for the learning management system (LMS) and send you information about courses that you may wish to complete before your start date. This is not mandatory and you will not be disadvantaged if you choose not to allow us to use your email address in this way or you do not complete the courses before your start date. If you do give us consent, you can withdraw it at any time by contacting the Home Administrator or Home Manager at your future place of employment.
If you register to be part of our Talent Network, we will use the information you supply to identify and notify you of job opportunities that may be of interest to you.
To we will also use the information you provide to generate statistics. These statistics are used to help us with management forecasting and do not identify individuals when they are reported across the organisation.
The General Data Protection Regulation (“GDPR”) requires us to identify one or more lawful bases for the processing of personal data. Our lawful bases are as follows:
• your consent (Article 6(1)(a)) – this is our lawful basis for processing personal data gathered through the Talent Network - you can withdraw your consent at any time by unsubscribing via the automatically generated emails - if you withdraw your consent you will no longer hear about our vacancies;
• to enter into a contract (Article 6(1)(b)) – i.e. to take steps at your request, before entering into a contract;
• to meet our obligations regarding employment (Articles 6(1)(c) and 9(2)(b)) – for example, if we undertake pre-employment checks regarding your suitability for the position; and
• to assess your working capacity (Article 9(2)(h)) – for example, if we undertake Occupational Health checks prior to employment.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require an NMC Pin check for this role and you fail to provide us with relevant details, we will not be able to take your application further.
Who we will disclose information to
We will disclose information to third parties who provide recruitment and selection services to us, such as recruitment agencies and system suppliers. The Talent Network and ATS are hosted by CareerBuilder LLC. The data you provide is stored on servers based in the UK and in the Republic of Ireland, however, CareerBuilder is a company based in the United States. It is EU-US Privacy Shield Framework certified, which means that it has been assessed as being compliant with data protection legislation. You can find CareerBuilder’s privacy notice here:
We use a software provider called, Evolve Assess, who help us create online assessment tools. Evolve Assess only store personal data in the UK and you can find their privacy notice here.
We sometimes use recruitment agencies to help us recruit colleagues. Some of these recruitment agencies are based outside of Europe to help us find international colleagues who are interested in coming to work for us. These recruitment agencies are usually data controllers in their own right, so we suggest that you check their privacy notices before signing up to use their services.
We will not share any of the information you provide with any third parties for marketing purposes.
When you make an application online (for example via our ATS)) or when you complete certain assessments (for example, around situational judgements) we may utilise online assessment tools to aid our decision making on your application. We use the reports from assessments to make a non-automated decision on your application. We need to do this in order to manage our recruitment process effectively and to ensure that all applicants that progress through the process meet our basic requirements for the role in question. The consequence of online testing will be to determine whether you proceed further in the recruitment process.
We may ask you certain situational judgement questions as part of our short-listing for the interview process. It is necessary for us to utilise this online decision-making process, given the potential volume of applications, to make a short list of possible candidates with the intention of entering into a contract with the successful applicant. The decision making is always non-automated.
We take the security of your personal data very seriously and have in place appropriate security measures at all times, including where we share your information with our suppliers and partners, to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal information to those employees, 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. We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please take care of your own information. For security tips and tricks when using the internet, Wi-Fi and smartphones or tablets, please visit www.getsafeonline.org.
How long we will use information for
Unless you explicitly agree otherwise with us (for example, you wish to remain on our records for potential future opportunities for a longer period), we will retain your personal information for a period of 12 months after either we have communicated to you our decision about whether to appoint you to the role or you have deactivated any online account you may have with us in relation to applications (whichever is the latter). We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.
If we wish to retain your personal information on file for a longer period, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately to let you know that we intend to retain your personal information for a fixed period on that basis. You can contact us at that time or at any time afterwards to ask us to remove your information, and we will do so.
We regularly review our retention periods to ensure that we are not keeping your data for longer than necessary. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. You may, in certain circumstances, also have the right to object where we are making automated decisions that significantly affect you.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer (contact details above).
Right to withdraw consent
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise in certain ways that we made clear to you at the time we obtained your consent. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact our Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.