Blackwell’s Candidate Privacy Notice

1. What is the purpose of this document?

Blackwell UK Ltd 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).

2. 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.

3. 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.

There are “special categories” of more sensitive personal data which require a higher level of protection.

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 any curriculum vitae and covering letter.
• The information you have provided on any application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• Any information you provide to us during an interview or the interview process.

We may also collect, store and use the following "special categories" of more sensitive personal information if you voluntarily provide it to us:

• 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.

4. How is your personal information collected?

We collect personal information about candidates from the following sources:

• You, the candidate.
• Recruitment agencies such as Harvey Nash, Way-Forward, Hays, Reeds, Robert Half, Champion, Michael Page from which we collect the following categories of data: Name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications
• Your named referees, from whom we may collect data on your employment history such as job title, main duties, start date, leave date, reason for leaving, performance in role including timekeeping and attendance and whether you were subject to recent disciplinary action.

5. How and why 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
   • Carry out background and reference checks, where applicable.
   • Communicate with you, and where applicable the recruitment agency, about the recruitment process.
   • Keep records related to our hiring processes.
   • Comply with legal or regulatory requirements.
   • Blackwell’s needs to process your data to enter into a contract with you.
   • In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, to check a successful applicant's eligibility to work in the UK before employment starts.

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

Having received the personal information surrounding your potential recruitment from the sources set out at Section 4 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.

5.2 If you give Blackwell’s a speculative CV i.e. email, post or hand in a CV where there is no specific role advertised (in the hope that your details will be considered for future vacancies) we will either destroy your CV where it is not likely that there will be a suitable vacancy or we will keep your CV as we have a legitimate interest in maintaining a talent pool to fill future vacancies. In this event we will keep your data for up to six months.

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

7. How we use particularly sensitive personal information

We will use your particularly sensitive personal information (if you volunteer it) 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 an interview.
• We may use information about your race or national or ethnic origin to ensure meaningful equal opportunity monitoring and reporting. In this event we will seek your consent.

8. Information about criminal convictions

 We do not envisage that we will process information about criminal convictions. However should this change we will let you know, alongside with the reasons for doing so.

9. Automated decision-making

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

10. Data sharing

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.

Blackwell’s will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you.

Blackwell’s will not transfer your data outside the European Economic Area.

11. 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 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.

12. Data retention

How long will you use my information for?

We will retain your personal information for a period of six months after we have communicated to you our decision about whether to appoint you. 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 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 or email you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

If you give Blackwell’s a speculative CV i.e. email, post or hand in a CV where there is no specific role advertised (in the hope that your details will be considered for future vacancies) we will either destroy your CV where it is not likely that there will be a suitable vacancy or we will keep your CV as we have a legitimate interest in maintaining a talent pool to fill future vacancies. In this event we will keep your data for up to six months.

13. 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 email our Data Protection Officer at [e-mail].

14. 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 at [e-mail] . 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.