Job Applicant Privacy Notice – THIS NOTICE IS AVAILABLE IN LARGE PRINT UPON REQUEST
Who is the Data Controller?
NSC Global Ltd, Third Floor, West Building, 1 London Bridge, London SE1 9BG – United Kingdom
Where the NSC group of companies (“NSC Group” or “NSC”) has an entity incorporated in another country, the applicable local entity will be the Data Controller.
Contact NSC’s Legal Department for any enquiries – [email protected]
As with any employment process, the NSC Group accumulates and processes personal data concerning job applicants. NSC is dedicated to being transparent about how it accumulates and processes that data and to meeting its legal obligations regarding Data Protection.
So, what information does NSC accumulate? Good question.
We accumulate a variety of information about you. This includes:
your name, contact details, address, including email address and contact number;
details of your employment history, skills, qualifications, and experience;
information concerning your present level of remuneration, including benefit privileges;
disability information, where you wish to provide this in order to request reasonable adjustments during the recruitment process; and
information concerning your entitlement to work in the country where the role you are applying for is based.
NSC accumulates this information in a variety of ways. For example, the data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
NSC will seek information from third parties only once a job offer to you has been made and will request your consent before it does this. This will include:
references supplied by former employers; and
information from employment background check providers and information from criminal record checks.
Data will be stored in a range of locations, including:
on your application record
in HR management systems; and
on other IT systems (including email).
But, why does NSC need to process personal data?
NSC needs to process data to take certain steps at your request prior to entering into a contract with you. NSC also needs to process your data to enter into a contract with you.
In some cases, NSC is required 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 within the country where their role will be based.
NSC also has a legitimate interest in processing personal data during the recruitment process and for keeping records of that process. Processing data from job applicants allows the NSC Group to:
manage the recruitment process
assess and confirm a candidate’s suitability for employment and
decide which candidate(s) to offer jobs to; and
NSC may also need to process data from job applicants to respond to and defend against legal claims arising from the recruitment process.
Where NSC relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of the data subject and has concluded that they are not.
In some circumstances, health information is processed to assess if reasonable adjustments are required to the recruitment process for candidates who have a disability. This is so that NSC can fulfil its obligations and candidates can exercise specific rights in relation to employment.
For some roles, NSC is obliged to seek information about applicants’ criminal convictions and offences. Where NSC seeks this information, it does so because it is essential for it to carry out its obligations and exercise specific rights in relation to employment.
NSC will not use your data for any purpose other than the recruitment process. If your application is unsuccessful, the organisation will keep your personal data on file in case there are future employment opportunities for which you may be suited. NSC will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
Fair enough, but who has access to this data?
Your information will be shared internally for the purposes of the recruitment process. 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.
NSC will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. NSC will then share your data with:
your former employer(s) or referee(s) to obtain references for you
employment background check providers to obtain necessary background checks and
selected third parties to obtain the necessary criminal records checks.
NSC will not transfer your data outside the European Economic Area unless a formal offer of employment has been offered and you have accepted – in which case, your data will be shared with some of our entities outside of the European Economic Area e.g. South Africa for payroll purposes. But don’t worry – the NSC group has in place an intercompany data processing agreement pursuant to the GDPR to permit such transfers of data. This agreement provides that any NSC entities receiving your data will keep it secure and confidential.
Ok, but will NSC protect my data?
NSC takes the security of your data extremely seriously and we ensure that privacy is at the heart of all of our processing activities. NSC has detailed internal policies, controls and binding corporate rules in place to ensure that your data is not lost, accidentally destroyed, misused or unnecessarily disclosed, and is not accessed except by our employees in the proper performance of their duties, on a need-to-know basis.
How long will NSC keep my data?
If your application for employment is unsuccessful, NSC will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow NSC to keep your personal data on file, NSC will hold your data on file for a further 6 years for consideration for future employment opportunities. At the end of that period (or once you withdraw your consent), your data will be deleted or destroyed immediately.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained for the duration of your employment plus an additional 6 years. More details will be provided to you in our Privacy Standards and Retention Schedule.
Do I have any rights?
Yes. as a data subject, you have a number of rights (provided that we are in receipt of suitable proof of your identity). You can:
access and obtain a copy of your data on request;
require NSC to change incorrect or incomplete data;
require NSC 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 NSC is relying on its legitimate interests as the legal ground for processing; and
ask NSC to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation’s legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact our Legal team at [email protected]
If you believe that NSC has not complied with your data protection rights, you may lodge a complaint to your local Data Protection Authority (DPA). To identify your local EU DPA, please click HERE.
What if I don’t provide any personal data?
You are under no statutory or contractual obligation to provide data to NSC during the recruitment process. However, if you do not provide the information, NSC may not be able to process your application properly or at all.
Are any automated decision-making processes involved?
No. Recruitment processes are not based on automated decision-making.