Processing

Privacy Policy

Towergate Privacy Statement

The following explains how we Towergate (Controllers) intend to use the information you provide in your application, along with your rights, our reasons for requesting it and who will have access to it.

As defined by the General Data Protection Regulation (GDPR) Towergate, 55 Bishopsgate, London is the Data Controller and ultimately responsible for ensuring the data you provide is kept secure, processed correctly and that you understand your legal rights in relation to the data you provide.

The recruitment software we use via this website is supplied by Net-Worx (2001) Ltd (trading as networx) and they are defined as a Data Processor under the GDPR. They will only process your data in accordance with our instructions.

networx can be contacted at: The Engine House, Wharfebank Business Centre, Ilkley Rd, Otley LS21 3JP.

The Data Protection Officer for networx is Rob Baker and can be contacted at dpo@networxrecruitment.com

Fair Processing Notice (Job applicants and recruitment)

The privacy and security of your information is important to us. This notice applies to individuals seeking employment or engagement with us. It explains who we are, the types of information we collect, how we use it, who we share it with and how long we keep it. It also informs you of certain rights you have regarding your personal information under current data protection law.  You can find out more about data protection from the Information Commissioner’s Officer here: https://ico.org.uk/.

Who are we?

<<Insert Data Controller entity/company /brand name>> (part of The Ardonagh Group of companies) is the Data Controller of the information you provide us and is registered with the Information Commissioner’s Office.

For general data protection queries you can contact us by email to DataProtection@ardonagh.com or in writing to The Data Protection Officer, care of the office of the Chief Information Officer, The Ardonagh Group, 55 Bishopsgate, London, EC2N 3AS. Please advise us of as much detail as possible to comply with your request.

For further information about The Ardonagh Group of companies please visit http://www.ardonagh.com/.

What information do we collect?

We and other Ardonagh Group companies on our behalf will collect information about you. Information will include your name, telephone number, email address, postal address, date of birth and other details. For example, this may include your employment history, references, ID, evidence of right to work, education and qualifications, current and expected remuneration, benefits expectations, interview notes, psychometric test results or companies house checks (depending on role), as well as any other information you choose to provide us with in support of your application (e.g. letters of introduction).

Information collated about you as part of your application and recruitment process may be provided by you or, in some cases, by an agent you have authorised to do so on your behalf. We may also obtain information from external sources such as referees and publicly available sources.

We may also use CCTV at our offices and calls made with our staff may be recorded, all of which may include information about you.

Sometimes we may need to request and collect particularly sensitive information about you. This might include information in relation to your health or medical records but certain other information is also deemed to be particularly sensitive. More information can be found at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/special-category-data/. Where we need this information we will obtain your explicit consent unless this is not required by law or the information is required to protect your health.

You may have already provided explicit consent for this information to be shared with us for the purpose of a job application via a recruitment agency or through someone you have authorised to act on your behalf.

How we use your information

We keep and process information about you for job application and recruitment purposes. This includes using information about you to enable us to assess or shortlist candidates, comply with any legal requirements, pursue the legitimate interests of The Ardonagh Group and to protect our position in relation to legal proceedings.

For example, we and other Ardonagh Group companies and third parties on our behalf will use your personal information (including sensitive information) to:

  • Assess and process your job application
  • Communicate with you or your authorised agent or representative about your application
  • Arrange any assessments, meetings or interviews as necessary
  • Enable relevant checks and screening to be undertaken to confirm who you say you are, your eligibility to work and that you are a reliable and trustworthy person to undertake the role you have applied for
  • Enable criminal record checks, where required for the role
  • Disclose any information where we are legally obliged to do so
  • Retain information that is necessary for continued engagement (for successful applicants)
  • Protect and further our legitimate interests as a business
  • Detect and prevent fraud or other criminal activity
  • We may check information provided to us against publicly available sources for accuracy

Securing your personal information

We and other Ardonagh Group companies follow strict security procedures in the storage and disclosure of your personal information, including storage in electronic and paper formats. If we provide information to a third party we will require it and any of its agents and/or suppliers to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Fair Processing Notice

Any new information you provide us may be used to update an existing record we hold for you.

When do we share your information?

We will share information within The Ardonagh Group of companies where it is necessary in connection with your application or recruitment.

We will also share information with third parties we use to carry out certain processes on our behalf as data processors, for example recruitment services, pre-employment screening and security checks as well as third parties and regulators requiring information such as the Department of Work and Pensions.

We may be obliged or allowed by law to pass on your information to the police or other law enforcement body or statutory or regulatory authority.

We may also share your information with anyone you have authorised to deal with us on your behalf.

The information we collect about you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for us or for one of our suppliers. Such staff may be engaged in, amongst other things, providing you with information you have requested or providing The Ardonagh Group companies with IT services.

How long do we keep your information for?

We will not keep your personal information longer than is necessary for the purpose for which it was provided unless we are required by law or have other legitimate reasons to keep it for longer, for example if necessary to protect our position in legal proceedings.

We and other Ardonagh Group companies will normally keep information for no more than 12 months after the application has ended unless you are successfully appointed, in which case we will retain information throughout the period of your employment (or engagement) and generally for no more than 7 years after you have ceased working for us.

Your rights

You have the right to request details of any personal information that we hold about you, to correct inaccurate information, and in certain circumstances the right to portability of information (i.e. requiring that your information is provided to others).  Additionally, under data protection law, where you have given your express consent for us to use sensitive information about you, you have the right to change or withdraw your consent.  If you do so, we will tell you about the consequences of that decision, including any legal reasons why we may still have to use your sensitive information on a limited basis. Where we have no legitimate reason to continue to hold your information, you have the right to be forgotten.

You also have a right to make a complaint to the Information Commissioner’s Office if you believe that we have not complied with our obligations.

If you are successful through the application stage, as part of our pre-employment checks, we will perform a number of background checks. We use the following provider(s) to handle your data in order to complete the checks on our behalf: Vero. For information on their privacy policy, please visit http://www.towergate.com/.

We collect your data for statistical analysis or to extract it as part of a successful employee process in to our HR/Payroll system.

How can I access the information you hold about me? Your rights

We are dedicated to providing reasonable access to visitors who wish to review the personal information retained when they apply via our website site and correct any inaccuracies it may contain. If you choose to register, you may access your profile, correct and update your details, or withdraw your details at any time. To do this, you can access your personal profile by using the secure login. In all cases we will treat requests to access information or change information in accordance with applicable legal requirements.

You have the following rights in relation to the way in which we deal with your personal data:

  • the right of erasure or to be forgotten
  • the right to rectification if information is inaccurate or out of date
  • the right of data portability (to obtain and reuse your personal data)
  • the right to object to networx and the controller and processors handling of your personal data
  • the right to withdraw your consent with regards to the handling of your personal data
  • you have the right to ask for a copy of the information we hold about you (Subject Access Request - S.A.R)
  • You have the right to lodge a complaint with a supervisory authority - the ICO

Within your candidate account, you can also use the Download Data feature to generate an XML file of the current data we hold on you that you have provided and/or have access to within the account.

Where you exercise your right to object or withdraw your consent we may process your personal data without your knowledge or consent where we are permitted or required by law or regulatory requirements to do so. In such a case, we will not process more personal data than is required under the circumstances.

If you are not satisfied by our actions, you can seek recourse through our internal complaints procedure. If you remain dissatisfied, you have the right to refer the matter to the Information Commissioner (www.ico.org.uk) or seek recourse through the courts.