Housing Solutions Internal Privacy Notice
Housing Solutions (“we”) are defined as a data controller and are responsible for your personal data under the General Data Protection Regulation (GDPR) and any successor legislation to the GDPR (collectively the “Data Protection Legislation”). We are registered with the Information Commissioner’s Office (ICO) under Z6037328.
How your information will be Collected and/or Used
In submitting an application to Housing Solutions you are required to provide the following data to us:
Personal data, on the legal basis of legitimate interests, which includes:
- Contact details (e.g. email address);
- Previous and current employment history;
- Educational background;
- Referee details (including contact information);
- Details of any unspent criminal convictions (if applicable, additional information to support any criminal reference checking);
- Equality and diversity data (if you explicitly consent to providing this data).
The data will be stored, processed, used and disclosed by Housing Solutions in the following ways:
- To provide our recruitment & selection services to you and to facilitate the recruitment & selection process;
- To enable you to submit your CV and/or application form;
- For us to answer your questions and enquiries.
Unsuccessful candidates’ data, for those who have applied through job train, will be retained by Housing Solutions on the system for 13 months after the last time you access your account. Your account will then be archived, at which point Housing Solutions will no longer have access to your data unless you opt to keep your account open. For all other candidates, your data will be securely destroyed after 12 months.
Successful candidates’ information required for employment purposes will be retained and processed in line with the ‘Employees’ section of this privacy notice.
1. As your employer, Housing Solutions needs to keep and process information about you for normal employment purposes. The information we hold and process will be used for our management and administrative use only.
We will keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately, during the recruitment and selection process, whilst you are working for us, at the time when your employment ends and after you have left. This includes using information to enable us to comply with the employment contract, to comply with any legal requirements, pursue the legitimate interests of the organisation and protect our legal position in the event of legal proceedings.
If you do not provide this data, we may, in some circumstances, be unable to comply with our obligations and we will tell you about the implications of that decision.
2. We may sometimes need to process your data to pursue our legitimate business interests, for example to prevent fraud, administrative purposes or reporting potential crimes.
3. Much of the information we hold will have been provided by you, but some may come from other internal sources, such as your manager, or in some cases, external sources, such as referees.
4. The type of information we process on the legal basis of legitimate interests includes:
- Your application form and reference;
- Correspondence with or about you (for example letters to you about a pay rise or, at your request, a letter to your mortgage company confirming your salary);
- Contact and emergency contact details (including beneficiary details);
- Records of holiday, sickness and other absence;
- Information needed for equal opportunities monitoring (if explicit consent is provided);
- Records relating to your career history, such as training records, appraisals, other performance measures and, where appropriate, disciplinary and grievance records.
The type of information we process using a contractual legal basis includes:
- Your contract of employment (and any amendments to it);
- Information needed for payroll, benefits and expenses purposes;
5. You will, of course, inevitably be referred to in many company documents and records that are produced by you and your colleagues in the course of carrying out your duties and the business of the company. You should refer to the Data Protection Policy which is available on the company intranet.
6. Where necessary, we may keep information relating to your health, which could include reasons for absence and GP reports and notes. This information will be used in order to comply with our health and safety and occupational health obligations – to consider how your health affects your ability to do your job and whether any adjustments to your job might be appropriate. We will also need this data to administer and manage statutory and company sick pay, private health care, car allowances, tool loans, health related allowance, physiotherapy, bike to work scheme and pay not to drive benefits.
7. Where we process special categories of information relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, biometric data
or sexual orientation, we will always obtain your explicit consent to those activities unless this is not required by law or the information is required to protect your health in an emergency.
Where we are processing data based on your consent, you have the right to withdraw that consent at any time.
8. In addition, we monitor computer and telephone/mobile use, as detailed in our ICT Acceptable Use Policy, available on the company intranet.
9. Other than as mentioned below, we will only disclose information about you to third parties if we are legally obliged to do so, for a legitimate interest or where we need to comply with our contractual duties to you. For instance we may need to pass on certain information to Civica (who manage our HR system), the Payroll Bureau (who perform payroll activities), insurance or pension brokers/providers).
10. Your personal data will be stored for periods outlined in our Data Retention Policy (with the majority of data being stored for a period of six years after your employment terminates).
1. What personal data do we process?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you the employee which we have set out below in section 2.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your employment with us.
2. Purposes for which we will use your personal data
3. Your rights in relation to your personal data
As a ‘data subject’ you have rights over the personal data we hold and process about you, specifically:
1. The right to be informed
Individuals have the right to be informed about the collection and use of their personal data
2. The right of access
Individuals have the right to access their personal data and supplementary information, including confirmation that their data is being processed.
3. The right of rectification
Individuals the right to have personal data rectified if it is inaccurate or incomplete.
4. The right to erasure (also known as the ‘right to be forgotten’)
This is also known as the ‘right to be forgotten’. Individuals can request the deletion or removal of personal data where there is no compelling reason for processing it.
5. The right to restrict processing
The processing of personal data may be restricted in certain circumstances, e.g. where the accuracy of the personal data is contested.
6. The right to data portability
Individuals have the right to obtain and reuse their personal data for their own purposes across different services.
7. The right to object
Individuals have the right to object to the processing of their personal data in certain circumstances.
8. Rights in relation to automated decision-making and profiling
Individuals have extra protections where automated decision-making (i.e. making a decision solely by automated means without any human involvement) is the sole method of decision-making.
These rights are set out in more detail on the ICO’s website www.ico.org.uk