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Privacy Policy

Waterloo Housing Group Limited Privacy Statement

As part of any recruitment process, Waterloo Housing Group Limited (the Group) collects and processes personal data relating to job applicants (also known as the data subject). The Group is committed to being transparent about how it collects and uses that data, and to meeting its data protection obligations.

This Privacy Notice explains what happens to any personal data that you provide to us, or that we collect from you. It tells you the purposes for which we may process your personal information and the legal basis for this.

For the purpose of the Data Protection Act 2018 and General Data Protection Regulation (GDPR), Waterloo Housing Group Limited is what is known as the data controller.

What information we collect

As part of the recruitment process, the Group collects and processes a range of information about you. This includes:

  • your name, address and contact details, including email address and telephone number, age range and gender;
  • details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with the Group and, employment references from third parties;
  • information about your remuneration, including entitlement to benefits such as pensions or insurance cover;
  • information about your nationality and entitlement to work in the UK;
  • information about your criminal record;
  • psychometric skills testing and related correspondence;
  • information about whether or not you have a disability for which the Group needs to make reasonable adjustments during the recruitment process; and,
  • equal opportunities monitoring information.

The Group collects this information in a variety of ways. For example, data is collected through application forms, CVs or resumes; obtained from your passport or other identity documents such as your driving licence; from forms completed by you, from correspondence with you; or through interviews, meetings or other assessments.

In some cases, the Group collects personal data about you from third parties, such as references supplied by former employers and information from criminal records checks permitted by law.

Data is stored in a range of different places, including in our paper and electronic personnel file, in the Group's HR management systems and in other IT systems.

What we do with the information we collect

The Group needs to process data to take steps prior to entering into a contract with you and then, where applicable, to enter into a contract with you.

In some cases, the Group needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.

The Group has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the Group to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide whom to offer a job. The Group may also need to process data from job applicants to respond to and defend against legal claims.

The Group processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

Where the Group processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

For some roles, the Group is obliged to seek information about criminal convictions and offences. Where the Group seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

Only if you are successfully recruited, we will upload your details to our HR system, Cascade. As a member of staff you will sign a contract of employment and agree to additional terms on how your data is handled and stored.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

The Group will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The Group will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

How long we keep data

If your application for employment is unsuccessful, the Group will hold your data on file for six months after the end of the relevant recruitment process. At the end of that period or once you withdraw your consent for us to hold this data, your data is deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

Security

We are committed to ensuring that your information is secure. All of our employees have contractual obligations of confidentiality, enforceable through disciplinary procedures. All employees will receive appropriate training on data protection and GDPR matters.

We take relevant organisational and technical measures to ensure the information we hold is secure – such as holding information in secure locations, restricting access to information to authorised personnel, protecting personal and confidential information held on equipment such as laptops with encryption. However, the transmission of information via the internet is not completely secure and so we cannot guarantee the security of data sent to us electronically.

Data processing

We may use the following data processors who act on our behalf to process prospective applicant data:

  • Networx Recruitment
  • Thomas International
  • Aston University
  • Boston College
  • Chesterfield College
  • South Leicestershire College
  • YMCA
  • Digital Apprenticeship Scheme
  • Recruitment Consultants

All these organisations are subject to the same legal rules and conditions for keeping personal confidential data secure. We ensure that our partner agencies have contracts /information sharing agreements which outline that your information is processed under strict conditions and in line with the law. Waterloo Housing Group Limited remains the data controller (the Group responsible for determining the purposes for which and the manner in which personal data is used under the Data Protection Act and General Data Protection Regulation 2018) of such information at all times.

Disclosing your information

Where applicable, we may disclose your personal information to any member of our Group, including our subsidiaries.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

There may be times when we may need to share personal information with third parties for the purposes outlined in this notice, or where we are legally required to do so. The main examples will be as follows:

  • To comply with the law or a court order;
  • In connection with any court proceedings or legal action; and,
  • To assist fraud protection and for safeguarding purposes.

You may request details of personal information which we hold about you under the Data Protection Act. If you would like a copy of the information held on you please write to Andrew Bush, Group Head of Policy and Communications at Waterloo Housing Group, 1700 Solihull Parkway, Birmingham Business Park, Solihull, B37 7YD.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the Group during the recruitment process. However, if you do not provide the information, the Group may not be able to process your application properly or at all.

What are your rights?

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require the Group to change incorrect or incomplete data;
  • require the Group to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where the Group is relying on its legitimate interests as the legal ground for processing; and,
  • ask the Group to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the Group's legitimate grounds for processing data.

You may request details of personal information which we hold about you under the Data Protection Act. If you would like a copy of the information held on you please write to Andrew Bush, Group Head of Policy and Communications at Waterloo Housing Group, 1700 Solihull Parkway, Birmingham Business Park, Solihull B37 7YD or email andrew.bush@waterloo.org.uk. We will need to first verify your identity in order to provide this information to you and will normally do so within 30 days from receipt of this. There may however be some exceptions to this where we will contact you within 30 days to advise of this.

Further information

If you wish to raise a complaint about how we have handled your personal data, please contact our Data Protection Officer who will investigate the matter. Our Data Protection Officer is Andrew Bush, Group Head of Policy and Communications and you can contact him at andrew.bush@waterloo.org.uk or 0121 788 7536.

If you are not satisfied with our response or believe that we are not processing your data in accordance with the law you can complain to the Information Commissioner's Office (ICO). You can contact the ICO at the following address:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.  Pleas also see http://www.ico.org.uk/