Data Protection Statement
Imperial College Healthcare NHS Trust Prospective Employee Privacy Notice
Imperial College Healthcare NHS Trust is committed to protecting the privacy of all prospective employees. This privacy notice explains your rights as a Trust service user, how we use information about you, and how we protect your privacy.
What this notice will tell you:
- Our legal basis for processing your data;
- Our purpose for processing your data;
- Whether you have to provide it to us;
- How long we store it for;
- Whether there are other recipients of your personal data;
- Whether we intend to transfer it to another country;
- Your rights and freedoms; and,
- How to lodge a complaint against the Trust to our regulatory body.
What information do we collect from you?
We require certain information in order to operate as an employer. Information such as, but not limited to personal identifiers, suitability to work for the Trust, skills and experience, bank account details, performance and disciplinary information.
What are our legal duties?
Imperial College Healthcare NHS Trust processes the information generated throughout the assessment and communication process on the basis of legitimate interest for recruitment and business management purposes.
Will the trust share your data with anyone else?
The Trust may in some circumstances need to share your information with third parties outside of the Trust. Some examples of this would be where the Trust provides a reference for you, discloses details about your employment to HM Revenue & Customs (HMRC), and with role-appropriate regulatory / supervisory bodies regarding fitness to practice.
The Trust will contact your nominated referees to collect reference information about you. This will occur either before interview (if you have indicated that this you are happy for the Trust to do so) or following the offer of employment to you. This will involve disclosure of the terms of your offer of employment and the requirement for a reference to be provided.
How long will the Trust retain the data?
We will only retain your personal data for as long as necessary for the purposes that the information was collected and for the purposes of meeting our legal obligations. We retain your information for a minimum of six years.
How is my data handled safely?
We have a legal duty to keep your data secure. Our staff undertake annual data security and protection training, and the Trust is subject to regular audits and independent reviews to make sure that we do keep your data safe. When we use other organisations to process your data, we ensure these processors comply with legal obligations to keep your data secure.
How can I access the information the Trust holds about me?
By law you are entitled to request a copy of the information we hold about you. This is known as a Subject Access Request. To submit such a request, we ask that you contact the HR Administration team at imperial.hr@nhs.net or the Medical Personnel team at imperial.medicalhradmin@nhs.net.
Who can I complain to?
The Information Commissioner’s Office (ICO) is the body that regulates the Trust under Data Protection and Freedom of Information legislation.
You can complain to the ICO at:
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Website: www.ico.org.uk/concerns
Telephone: 0303 123 1113.
The Trust is registered as a data controller under the registration number Z1152836.
Your privacy is important to us. This data protection statement covers the data collected during the recruitment process. The recruitment process may start with the registration and attendance at a career / marketing event as well as searching and applying for jobs and then the progression of your job application through the process to the point of hire.
This statement explains what personal data we collect from you during the recruitment process, through our interactions with you and through our products and how we use that data.
We expect to collect a lot of information about you during the process and we require some information which we can communicate, make recruitment decisions, and complete a contract of employment. We may ask for other optional information to help us deliver a better recruitment experience.
Where information is optional, we will need your consent to collect the information and we will make this clear during the recruitment process. If you do not choose to give consent, or you choose not to supply optional information, then this will not impact the recruitment decisions we make about you.
Personal Data We Collect
During the recruitment process we may ask you to provide information, we may record other sources of information about you (e.g. feedback from recruiters), and we may infer or derive other data (e.g. determine your location from your postal code or count up the number of languages you speak). The types of collated information include:
Personal Contact
Names, e-mails, address, phone numbers etc.
Screening/Selection Information
Your CV / Resume, education results, work experience, significant achievements, etc.
Some of this information would not be personal to you if all other fields were anonymised e.g. your location preference is considered personal data while linked to other personal contact information but it cannot be used to personally identify you its own. Some of this information may include enough information to personally identify you e.g. your CV/Resume.
Evaluation Data
Information provided by other people involved in the recruitment process about your suitability for employment and your status within the recruitment process.
Your feedback on the recruitment process
Optional information provided by you about your views on the recruitment process.
Special Requirements
Optional information provided by you e.g. medical needs, dietary requirements, disability, dyslexia, study abroad.
Candidate Contractual Information
Information provided by you which is required for final contract (in addition to Personal Details). Includes acceptance of offer.
Other Contractual Information
Information added by us in order to draw up contract e.g. salary, job title, hours.
On-Boarding Information
Additional information supplied by you in order to complete the hiring process and may include bank details, proof of right to work, next of kin, etc.
Equal Employment Opportunity (EEO) Information
Gender, Race, Religion, Veteran, Disability, or other diversity information
How We Use Personal Data
Personal Contact data is used to communicate with you during the recruitment process.
Screening/Selection data is used to decide on your suitability for jobs that you apply to or to identify jobs for which we think you may be more suitable.
Evaluation data is used to record our assessment of your suitability for jobs that you are being considered for and your status within the recruitment process.
Your Feedback data is used by us to improve the recruitment process for future candidates.
Special Requirements data is used by us to make accommodation in the recruitment process for any needs you may have.
Candidate Contractual Information and Other Contractual Information is used to compile contractual documentation (e.g. job offer and contract) and to record the contract. If you accept an offer of employment then some of this data will be transferred to other systems that we control (e.g. payroll systems).
On-Boarding Information is used by us to prepare for you starting work with us including setting up payroll information, benefits, and proof of right to work. If you accept an offer of employment then some of this data will be transferred to other systems that we control e.g. payroll systems.
EEO Information is used to monitor the recruitment process to ensure our recruitment practices are fair.
We may aggregate data with other candidate’s data in reports to help us monitor, improve, and plan our recruitment activities. These reports will not include personally identifiable information.
Length of Time We Retain Your Data
If you are successful and you accept an offer, the data may be retained throughout your employment and for a period after the end of employment. In this case you will be informed of further data retention policies as appropriate.
If you are not made an offer, or you do not accept an offer, then we keep the data, including personally identifiable data, for 1 year after the end of recruitment activity so that we can refer to it in case of queries over the recruitment process, including employment tribunals or other legal challenges.
After the 1 year retention period we will anonymise all your data. Any data that may contain personally identifiable information will be cleared. The data that we retain is used to report on the historical performance of our recruitment process.
Reasons We Share Personal Data
We share data within our controlled affiliates and subsidiaries and other vendors working on our behalf. For example, companies we've hired to provide the recruitment technology and to support this recruitment process, or companies to assist in protecting and securing our systems. In such cases, these companies abide by our data privacy and security requirements and they are not allowed to use personal data they receive from us for any other purpose. We may disclose personal data when required by applicable law or to respond to legal process.
We do not sell, rent, and trade your personal data.
Your rights: How to Access and Control Your Personal Data
You have the right of access and the right to rectify the data concerning you. You can view much of your personal data through this website. You can request a copy of your personal data by contacting the address below.
You can rectify or correct personal data if you find it is inaccurate or incomplete. Much of the information can be updated by you using this website. If there are other changes that you need to make then you can provide details of changes to the address below. The right of rectification can only apply to factual data processed within the recruitment process. Data related to the screening / selection criteria cannot be rectified after the closing date of submitting applications as this data is used at that time to make decisions and needs to be preserved in that state as evidence in case of challenges to the fairness of the process.
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