What is the purpose of this document?
Burnetts is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).
It applies to all those individuals who participate in our work experience scheme.
Burnetts is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to current and former work experience scheme participants. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.
It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
Data Protection Officer
We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. Our Data Protection Officer is Vaughan Jones who can be contacted on 01228 552222 or firstname.lastname@example.org. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. 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.
Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must 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 it 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.
Your Personal Information
The kind of information we hold about you
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).
There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.
We will collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Marital status and dependants.
- Next of kin and emergency contact information.
- Details of your education, including grades and achievements, and your education establishment.
- Data about what specific skills you have.
- National Insurance number.
- Start and end date of your placement.
- Location of employment or workplace.
- Recruitment information (and other information included in a CV or cover letter or as part of the application process).
- Information about your use of our information and communications systems.
We may also collect, store and use the following more sensitive types of 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.
How is your personal information collected?
We collect personal information about our work experience scheme participants through the application process, directly from candidates. Specifically, from your CV or cover letter, interview or another form of assessment.
We will collect additional personal information during the course of your placement.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
* Where we need to comply with a legal obligation.
* Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
* Where we need to protect your interests (or someone else’s interests).
* Where it is needed in the public interest.
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to fulfil our obligations towards you during your placement and to comply with our legal obligations. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
- Making a decision about your recruitment or appointment.
- Determining the terms on which you work for us.
- Checking you are legally entitled to work in the UK.
- Assessing qualifications for a particular job or task.
- Making decisions about your continued engagement with the firm.
- Making arrangements for the termination of our working relationship.
- Education, training and development requirements.
- Dealing with legal disputes involving you, including accidents at work.
- Ascertaining your fitness to work.
- Managing sickness absence.
- Complying with health and safety obligations.
- To monitor your use of our information and communication systems to ensure compliance with our IT policies.
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
- Equal opportunities monitoring.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:
* In limited circumstances, with your explicit written consent.
* Where we need to carry out our legal obligations or exercise rights in connection with the scheme.
* Where it is needed in the public interest, such as for equal opportunities monitoring.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Situations in which we will use your sensitive personal information
In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with your work placement. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process your particularly sensitive personal information are listed below. We have indicated the purpose or purposes for which we are processing or will process your more sensitive information.
- We will use information about your physical and mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work and to provide appropriate workplace adjustments. We need to process this information to exercise rights and perform obligations in connection with your work placement.
- 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.
Do we need your consent?
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. 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 you are not obliged to agree to any request for consent from us.
Information about criminal convictions
We do not envisage that we will hold information about criminal convictions.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes third party service providers.
How secure is my information with third-party services providers?
All our third-party services 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.
We have put in place measures to protect the security of your information. Details of these measures are available upon request or can be found on the Intranet.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and keep it secure.
How long will you use my information for?
We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to continue your engagement with the firm. 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 and the applicable laws and regulations.
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 duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
- 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 our Data Protection Officer, Vaughan Jones in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Vaughan Jones. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Changes to This Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact Vaughan Jones, our Data Protection Officer.