Privacy Notice for Role Applicants

WHAT IS THE PURPOSE OF THIS DOCUMENT?

Motorplus Limited t/a Coplus and Brokerplus is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, 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).

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 application for work with us, we will collect, store, and use the following categories of personal information about you:

  • The information you have provided to us in your curriculum vitae and covering letter.
  • The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, and qualifications
  • Any information you provide to us during an interview.

We may also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Information about your health, including any medical condition, health and sickness records.
  • Information about criminal convictions and offences.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We collect personal information about candidates from the following sources:

  • You, the candidate.
  • Recruitment agencies, from which we collect the following categories of data: information that you have provided to us in your curriculum vitae, covering letter or any further information you have provided to the relevant recruitment agency including name, title, address, telephone number, personal email address, date of birth, gender, employment history or qualifications.
  • Your named referees, from whom we collect the following categories of data: Your previous job roles, date of employment, ability to perform your previous jobs role, any previous disciplinary or conduct issues, absence records and any character references about you.
  • Third parties such as Experian where we are required to undertake criminal records checks and/or financial checks on you for the purposes of compliance with our legal and/or regulatory obligations.

HOW WE WILL USE INFORMATION ABOUT YOU

We will use the personal information we collect about you to:

  • Assess your skills, qualifications, and suitability for the role for which you have applied
  • Carry out background and reference checks, where applicable.
  • Communicate with you about the recruitment process.
  • Keep records related to our hiring processes.
  • Comply with legal or regulatory requirements.

It is in our legitimate interests to decide whether to appoint you to a role since it would be beneficial to our business to appoint someone to that role. We also need to process your personal information to decide whether to enter into a contract of employment with you. Having received your CV and covering letter 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 will then take up references and because we are regulated by the Financial Conduct Authority we may, depending on the role, carry out a criminal record check before confirming your appointment. We will inform you if we required to undertake criminal record checks prior to this being undertaken.

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 a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION

We will use your particularly sensitive personal information in the following ways:

  • We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

We will use information about criminal convictions and offences to assess whether you meet the legal requirements for the role.

INFORMATION ABOUT CRIMINAL CONVICTIONS

Depending on the on role you are applying for we may process information about criminal convictions.

We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are required to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular where:

  • We are legally required to carry out criminal record checks for those carrying out the role you are applying for.
  • If the role you are applying for requires a high degree of trust and integrity (for example the role involves dealing with high value funds) and so we would like to ask you to seek a basic disclosure of your criminal records history.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

We will notify you during the application process if the role you are applying for requires any checks of this nature. You have the right to refuse these checks. However, this may mean that we are not able to progress your application, where your refusal conflicts with our legal or regulatory duties.

AUTOMATED DECISION-MAKING

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

DATA SHARING

We may need to share your data with third parties for the purposes of processing your application and determining your eligibility to work in the role you are applying for.  We may have to share information about your nationality with HMRC to determine whether you have the right to work in the United Kingdom.  We may have to share information with a provider of criminal records checking and/or financial checks (for example Experian) so that they can provide their services and complete such checks. This will only apply to certain roles, and you will be informed about this prior to such a check being conducted.

DATA SECURITY

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 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 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.

DATA RETENTION

How long will you use my information for?

We will retain your personal information for a period 6 months after we have communicated to you our decision about whether to appoint you to the role. 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, 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, seeking your explicit consent to retain your personal information for a fixed period on that basis.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

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.
  • 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 the Data Protection Officer in writing.

DATA PROTECTION OFFICER

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO as follows: By email to: dpo@coplus.co.uk

In writing to: Floor 2, Norfolk Tower, Surrey Street, Norwich, NR1 3PA.You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

ADDITIONAL MEASURES IN RESPONSE TO COVID-19

The health and safety of our employees (including applicants) is of great importance to us. Therefore, in response to the COVID-19 pandemic, we have taken additional steps to protect the health of our employee and you. Some of these steps may involve collecting and processing additional information about yourself. These additional measures do not affect your rights in connection with personal information, nor do they override any other provision of this Privacy Notice. We collect and process this information on the basis of legitimate interests, as this processing is in your interests, our interests, and the interests of the public health efforts to tackle COVID-19. Some of these measures may also fall under our legal requirement to comply with health and safety in the workplace.

We will use this information for the purposes of completing appropriate workplace health and safety risk assessments, designed to help protect yours and our employee’s health in the workplace during the ongoing COVID-19 pandemic. How we will collect and use the particular types of data is explained in more detail below. Whilst you do not have to provide this information, providing it will assist us in more accurately completing a health and safety risk assessment. For the avoidance of doubt, these additional measures in place during the COID-19 pandemic do not affect any of your rights under the UK GDPR (including access and erasure).

Vaccination Status

In the event that you are invited to attend an in-person interview, we may ask you about your vaccination status, so that we can complete a risk assessment in the interest of protecting your health and that of our employees. However, you do not have to provide this information. In the event that you do not provide this information you will not receive detrimental treatment as a result of this decision.

We will retain this information whilst it is necessary to appropriately complete health and safety risk assessments in regards to COVID-19. This data will be deleted when it is no longer necessary for these purposes, or if your application is unsuccessful it will be deleted at the end of the application process.

Clinically Vulnerable/Vulnerable

In the event that you are invited to attend an in-person interview, we may ask you if you are clinically vulnerable or vulnerable, so that we can complete a risk assessment in the interest of protecting your health, during the COVID-19 pandemic. However, you do not have to provide this information. In the event that you do not provide this information you will not receive detrimental treatment as a result of this decision.

We will retain this information whilst it is necessary to complete health and safety risk assessments, in regards to COVID-19. This data will be deleted when it is no longer necessary for these purposes, or if your application is unsuccessful it will be deleted at the end of the application process.

Temperature

In the event that you are invited to our offices, we may request you to take your temperature. We do not record this information. However if you have a fever you may be asked to leave the building. You will not receive any detrimental treatment if you do or do not have a high temperature.

CCTV

To reduce contact with door handles, and mitigate transmission of diseases, doors within the office are left open during core office hours. To ensure the premises are still secure, CCTV is in place recording all entrance and exit points to Floor 2 of Norfolk Tower where our office is located. This footage may capture your image when you use these entrances and/or exits. This data is used solely for the purposes of ensuring no unauthorised person(s) enter the premises. This data is retained for a period of 2 weeks and then destroyed.

NHS Test and Trace (Isolation)

In the event that you have been instructed to self-isolate by NHS test and trace, and this conflicts with any in-person interview you may have been invited to, we may collect data about this if/when you tell us. We will use this information to provide suitable alternatives, where we can, such as videoconferencing solutions, or moving the date of any such interviews. You will not be subject to any detrimental treatment as a result of providing this information.

If you have any questions about this privacy notice, please contact the Data Protection Officer at dpo@coplus.co.uk