Privacy Notice – Job Applicant

Lifeways Group understand that the privacy and security of your information is important. This notice is to inform you what data we hold about you and why, what we do with that data, and informs you of your rights regarding the personal information we hold under current data protection law.

Who we are

Lifeways, registered at No 2. The Square, Birchwood Boulevard, Warrington, WA3 7QY is the Data Controller of the information covered by this privacy notice. Hireserve, our third-party provider of our recruitment management software, is our Data Processor.

Lifeways Group is a responsible and ethical employer. We regard the lawful and fair treatment of personal data as very important to maintaining confidence between you and us.

What information we hold and why

Lifeways Group will collect and process personal data about you during your job application process to determine your eligibility and suitability for employment. This includes checking your eligibility to work in the UK and, where relevant for certain roles, checking your criminal record information. We process your personal data listed below for the following purposes:

• to enable us to comply with our legal and regulatory obligations.
• to make recruitment decisions
• to monitor equal opportunities.
• to comply with the duty to make reasonable adjustments for disabled job applicants and with our disability discrimination obligations.
• to prevent and detect fraud and other wrongdoing; and
• to establish, exercise or defend our legal rights.

The personal data we process during your application includes:

• Your name, home address, email address and/or phone numbers.
• Your date of birth, gender and National Insurance number (where you provide this to us);
• Your CV or other documents or information provided by you.
• Right to Work Documentation, such as a copy of your passport.
• Information needed for compliance and risk management, such as background check reports, DBS/PVG checks.
• References from previous providers or other referees

We also collect the following special category information:

• Health details relevant to the job you are applying for.
• Sexual orientation (by means of material status and preferred pronouns)
• Religion
• Ethnicity

What is our lawful basis to obtain and use your personal information?

Processing of the above the personal data is necessary for us to consider your application and/or comply with statutory requirements relating to immigration taxation and the protection of the health of vulnerable people.

To lawful basis relied on by Lifeways to process job applicant personal information is:

• processing is necessary for the performance of or steps leading to a contract (employment contract) (Art6(1)(b) GDPR)
• where we have a statutory obligation to conduct certain checks, such as Right to Work Checks or DBS and background checks, our lawful basis is defined by Art 6(1)(c) GDPR.
• Processing is necessary for the purposes of the legitimate interests of Lifeways or its services users (Art6(f) GDPR).

For special category data, which is more sensitive information, we rely on the following:

• processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment (Art9(2)(b) GDPR)
• processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, the provision of health or social care or treatment or the management of health or social care systems and services (Art9 (h) GDPR)

Where we obtained your information

Lifeways Group will obtain data directly from you (for example, through our website, the telephone or by email) as well as through third parties such as recruitment agencies or job boards. We may also obtain information about you from referees you nominate, and from statutory registers such as DBS information.

We may also obtain information about you from open public profiles available online such as LinkedIn.

Who we share the information with

Your details may be passed onto third parties, but that is not for any purposes other than the purposes mentioned above. Categories of third parties we routinely share job applicant information with are as follows:

• Third parties engaged to carry out services or functions on our behalf. For example, criminal bureau checking services, medical questionnaires, psychometric evaluation or skill tests forming part of the recruitment process.
• government bodies and law enforcement agencies to comply with any legal obligations, or to protect the rights, property or safety of our staff, our company or others.
• Referees you nominate, or previous employers you refer to in your application.

How long we keep your information

Lifeways policy is to retain personal data only for as long as needed to fulfil the purpose(s) for which it was collected, or otherwise as required under applicable laws and regulations. Under some circumstances Lifeways may anonymise your personal data so that it can no longer be associated with you. We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice to you.

If you application is successful and you commence employment with Lifeways, the information collected during your application will form part of your employment records and kept in accordance with Lifeways retention policy.

If your application is unsuccessful, the information collected during your application will be retained for 12 months from the date the role you applied for is filled. After this date, we may anonymise your application for statistic reporting. We will delete any anonymised applications.

If you consent to Lifeways Group keeping your personal information on file, in case there are suitable future employment opportunities with us, Lifeways Group will hold your personal information for a further 12 months after the end of the relevant recruitment exercise, or until you withdraw your consent if earlier.

How do we keep information secure?

The security of your personal information is important to us. The records we keep about you are secure and are confidential within Lifeways. Lifeways have a range of procedures, polices and systems to ensure that access to your records are controlled appropriately. Anyone who receives information from us is also under a legal duty to only use the information for the purposes agreed and keep the information secure and confidential.

Transfer outside of the EEA

We do not send your data outside of the EEA.

Profiling

No automated profiling or decision-making on job applicants will take place.

Your rights

Lifeways Group recognise the rights of the data subject regarding this data processing. As a data subject, you have:

• the right to access personal data held, and to portability.
• the right to rectification should any errors be noticed.
• the right to erasure.
• the right to restrict processing, e.g. by asking us not to send marketing communications to you;
• the right to be informed
• the right to lodge a complaint with the supervisory authority (The Information Commissioner’s Office).

Should you wish to invoke any of your rights, or have any queries about the information we hold about you, please contact us by one of the following methods:

Email: dpo@lifeways.co.uk

Post: Data Protection Officer, The Lifeways Group, No. 2 The Square, Birchwood Boulevard, Warrington, WA3 7QY

Tel: 0207 202 6300

Information Commissioner's Office

The Information Commissioner is the UK's independent body for upholding information rights. Visit their website to find out more about your rights under Data Protection law, and what to expect from us.

For privacy practices or data protection rights concerns, contact the Information Commissioner's Office:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

0303 123 1113 or 01625 545 745

casework@ico.org.uk