Our Recruitment Privacy Notice describes how we handle and protect your data throughout the recruitment process. Please read this Notice carefully. By continuing with your application, you are agreeing for Redwood Bank (the “Bank”) to collect and use your personal information for the purposes of recruitment, selection and interview (“recruitment process”).
We are committed to respecting your privacy and protecting your personal data which is any information that is capable of identifying you as an individual. This Notice describes how we handle and protect your personal data in connection with the Bank’s recruitment process. This Notice applies whether your application is received directly by the Bank or via a job board or recruitment agency.
Information we collect
The Bank is committed to being transparent about how it collects and uses personal data and to meeting its data protection obligations.
This Notice applies to the processing of personal data in relation to the recruitment process, if you are successfully employed by the Bank you will be provided with a new Notice which explains the additional processing which will take place during and after your employment with the Bank.
From the point at which we receive your application for employment with the Bank the Bank will need to maintain and process data about you for the purposes of reaching and communicating a recruitment decision and making an offer of employment if appropriate.
How information is collected
We collect personal information about you from the following sources:
- You, the candidate;
- Recruitment agencies who submit your application to us on your behalf.
Types of personal data we process
The types of data the Bank may collect about you during the recruitment process includes:
- Your name; contact details and address
- Your gender profile; age profile and ethnicity;
- Details of your skills, qualifications, experience and employment history;
- Any other detail included on your application not captured above;
- Information regarding your right to work in the UK;
- Details regarding your current level of remuneration and any work benefit entitlements; and
- Information you directly give to us as to whether or not you have a disability for which the business needs to make reasonable adjustments during the recruitment process.
- Information about criminal convictions and offences.
How and why we process personal data
The lawful basis for processing which we will rely on as defined in data protection legislation such as the UK Data Protection Act 2018 and the UK GDPR will be:
- With your consent.
- In contemplation of an employment contract with you.
- For our legitimate interests where those interests do not override your fundamental interests.
- Where we need to comply with our legal obligation such as under employment, social security and social protection law.
- For your vital interests but only in cases of emergency.
Where we use consent to process your personal data, you will be asked to confirm your consent at application stage, you are able to withdraw your consent at any time, however if you do, we will not be able to proceed with the recruitment process.
We have set out below in a table format a description of the ways we plan to use your personal data and which of the legal basis we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Lawful basis for processing |
|---|---|
|
Use of HiBob |
With your consent or the consent that you have given to recruitment agency to upload details onto HiBob. |
|
We will process contact details you give us to contact you to progress your application. We may also contact you to request your feedback about our recruitment process. |
Processing necessary to perform a contract or to take steps at your request, before entering a contract. For the purpose of our legitimate interests to monitor our recruitment process. |
|
For processing recruitment information to assess your suitability for a role you have applied for and to help us develop and improve our recruitment process. |
Processing necessary to perform a contract or to take steps at your request, before entering a contract. For the purpose of our legitimate interests to improve our recruitment process. |
|
To participate in assessment days; complete tests or occupational personality profile questionnaires; attend an interview; or a combination of these. |
Processing necessary to perform a contract or to take steps at your request, before entering a contract where there is a requirement for the role to complete assessments. For the purpose of our legitimate interests to ensure our employees have the competencies and skills to perform their roles. |
|
If you provide us with any information about reasonable adjustments, you require under the Equality Act 2010 |
To comply with our legal obligations. |
|
Where you provide us with any information as part of your application which is special category data, such as health, religious, sexual orientation or ethnicity information. |
Explicit consent. |
|
Processing for equal opportunities information. This is not mandatory so if you do not provide it, it will not affect your application. This information will not be available to any staff outside our recruitment team, including hiring managers, in a way that can identify you. |
Legal obligation – Note any information you provide will be used to produce and monitor equal opportunities statistics and will not identity you. This information may also be shared with external equality and diversity auditors. |
Additional Information about HiBob
Personal data collected will be stored in electronic format (including emails) within our recruitment system in HiBob. A link to their Privacy Policy is available here.
The Bank uses all reasonable efforts to ensure that any personal information collected is held securely and remains within the UK/EEA.
HiBob maintains offices in the EU, UK, US, Israel, Canada and Australia, therefore your personal data may be accessed from any of those locations or other locations as reasonably necessary for the Hiring Module’s activity by HiBob employees tasked with handling Redwood Bank’s data. Such access usually occurs in the course of providing customer support or technical assistance. Appropriate controls are in place to ensure that your data is protected. For further information see International Transfers.
Sharing Information
Your information will only be shared internally for recruitment decision making purposes.
We will not share any of the information you provide with any third parties for marketing purposes.
Your data subject rights
Under certain circumstances you have the following data subject rights. Note not all rights are absolute so do get in touch if you need further explanation on which rights have conditions attached to it.
- Request access to your personal information which is 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. Where we are relying on your consent or our legitimate interests to process data you have the right to ask us to delete or remove personal information. 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 the personal information supplied to us by yourself, to another party.
If you wish to exercise any of your rights, please choose the options for making data access, deletion and correction requests which is available to you through the candidate portal. This is accessible through the link that is included in email communications you will receive throughout the recruitment process, or you can submit your request to the Data Protection Officer.
No fee usually required
You will not have to pay a fee to access your personal information or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity to ensure you have the right to access the information or to exercise any of your other rights. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
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, agents, contractors and other third parties 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.
Retention
Where we do not make an offer of employment your recruitment information is normally retained for a maximum of six months following completion of our recruitment process in accordance with our retention policy.
Where an offer is made your personal data will be retained in line with our People Team retention periods.
International Transfers
Our use of HiBob will mean that your personal data can be stored outside of the UK/EEA as described in Further Information about HiBob. When we transfer your personal data outside of the UK we ensure or require the service provider to confirm that there are safeguards in place or transfer personal data that has the same level of data protection as that afforded by the UK Data Protection Act 2018 and the UK GDPR.
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or
- We will use specific contracts approved for use in the UK which give personal information the same protection it has in the UK. For example, the use of Article 46 UK GDPR safeguard mechanisms to transfer personal data endorsed by the UK Government.
Issues and Concerns
We would appreciate the chance to deal with your concerns in the first instance so please contact us. See Contact details.
If you have unresolved concerns and you live or work in the UK or believe that a personal data breach happened in the UK you have the right to complain at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk ).
If you live or work outside the UK or you have a complaint concerning our personal data processing activities you may lodge a complaint with another supervisory authority.
Contact details
Should you have any questions or queries regarding the handling of your data you can contact our Data Protection Officer at the following email: DPO@redwoodbank.co.uk and the following address: Redwood Bank, The Nexus Building, Broadway, Letchworth Garden City, Hertfordshire, SG6 3TA.