Candidate privacy notice
How we obtain your personal data
We collect personal data (including CVs) for the purposes of recruitment from the following sources:
- Directly from you: Where you apply directly to us, via our online recruitment system or via our website. If you are invited for an interview, the interviewing panel may record information you provide during the interview.
- From publicly available sources: We may obtain your personal data from recruitment and social networking sites.
- From our third-party recruitment agencies: Our recruitment agency partners may send us your CV directly or recommend you for a current vacancy.
- From our third-party background/vetting partner: If you are offered a role within the NWF, we will use our third-party employment screening partner to carry out background and financial checks, including references.
- From references that you provide: Your references will be contacted to assess your suitability for the role.
What information we process
In the recruitment process, we will typically collect the following personal data:
- Basic personal identifiers: such as your name, email address, telephone number, home address, D.O.B, gender.
- Education: details about your educational background, such as where you attended school, college or university, and any qualifications you have obtained.
- Identification documents: Government-issued documents such as passports, right to work documents.
- Employment: details about your work history, including where you have worked and any professional qualifications you have obtained that may be relevant to the role you are applying for.
- Criminal conviction records: details relating to any criminal convictions you hold, or the absence of any criminal records.
- Personality/psychometric testing: when applicable, we may request that you take a personality/behavioural test. This will highlight your preferred working style and your personality type.
- Background/ethnicity: we may process details relating to your ethic origin or religious beliefs. This is to support our goal of creating equality of opportunity within the NWF. Where we do process this information, we will remove any personal identifiers (so that it cannot be linked back to you) after a period of 12 months.
- Health: we may need to process data about your health to make reasonable adjustments to allow you to attend an interview. This is a legal obligation we have under the Equality Act.
Additionally, if you are offered a role with us, we will process the following categories of personal data:
- Financial: If you accept a role, we will process details relating to your bank account so that we can pay your salary, as well as background credit checks.
- Criminal conviction records: details relating to any criminal convictions you hold, or the absence of any criminal records. This may include screening against the Cifas Insider Threat database.
Our purposes (and lawful basis)
| Purpose | Lawful basis | Our legitimate interests |
|---|---|---|
| To assess your suitability for the role | UK GDPR Article 6 (1) (f) - Legitimate interest | To ensure that we are offering the role to the most qualified candidate |
| To verify you have the right to work in the UK | UK GDPR Article 6 (1) (c) - Legal obligation | N/A |
| To assess your working style and personality profile | UK GDPR Article 6 (1) (f) - Legitimate interest | To ensure that you will be a good fit within the culture of the NWF |
| To promote diversity and equality of opportunity within the NWF | UK GDPR Article 6 (1) (f) - Legitimate interest | To ensure that we are operating as an equal opportunities employer and providing fair treatment to all candidates |
| To make reasonable adjustments to ensure you are given fair treatment throughout the recruitment process | UK GDPR Article 6 (1) (c) - Legal obligation | N/A |
In some cases, we process more sensitive ‘special category’ data. This is data which is typically more sensitive and carries a higher risk. Special category data is any of the following: health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, sex life and sexual orientation.
Where we process this type of data, we need to identify an additional lawful basis for this processing. We rely on the following bases for the processing of special category data:
| Special category/ sensitive data | Lawful basis |
|---|---|
| Race or ethnic origin, religious or philosophical beliefs | UK GDPR Article 9 (2) (g) – substantial public interest Data Protection Act 2018, Schedule 1, Part 2 (8) – equality of opportunity or treatment |
| Criminal conviction data | Data Protection Act 2018, Schedule 1, Part 2 (10) – preventing or detecting unlawful acts |
| Health data (to make reasonable adjustments) | UK GDPR Article 9 (2) (b) – employment Data Protection Act 2018, Schedule 1, Part 1 (1) – employment, social security or social protection |
Who do we share personal data with?
We typically share your personal data with the following organisations:
- Workday Inc - supply us with our online recruitment system.
- Employment screening partner – perform background checks on our behalf as part of the onboarding process (if you are offered a role). We share basic personal details with them so that background checks can be commenced.
- Disclosure and Barring Service (DBS) – we will share basic information with the DBS so they can undertake relevant checks. For more information on this process, please contact the DBS.
- Cifas - The personal data we have collected from you will be shared with Cifas who will use it to prevent fraud, other unlawful or dishonest conduct, malpractice, and other seriously improper conduct. If any of these are detected you could be refused certain services or employment. Your personal information will also be used to verify your identity. Read more about how your information will be used by us and Cifas, and your data protection rights.
We will also share your data internally with the relevant hiring manager or interviewing panel. We only provide access to recruitment data where there is a legitimate need to do so.
How long do we keep your data?
As a rule, we will only retain your data for as long as we have a purpose to process it. Once we no longer have a purpose to continue processing it, we will securely erase it. The following table shows the different periods and our purposes for retaining it:
| Type | Period |
|---|---|
| Unsuccessful candidates | We will retain all details related to your application for a period of 6 months, unless you have opted into our 'talent pool'. We keep this information to establish or defend any legal claims relating to our recruitment process. |
| Successful candidates | All information will be transferred to our HR file where it will be kept for the period of your employment (and subject to the relevant NWF retention period after you leave). |
| 'Talent pool' | During the application, you have the option to join our talent pool. We keep your application details on record for a period of 2 years. If we think a future role may be of interest, we may contact you about it. |
Where do we share your data?
For the recruitment process, we will only share your data with the relevant members of our HR team, the hiring manager, and the interviewing panel. Apart from the organisations listed above in the ‘who do we share personal data with’ section, your data won’t be shared outside of the NWF.
For our use of Workday, your personal data may be transferred to the United States. Workday are certified to the EU-U.S. Data Privacy Framework.
Your data protection rights
You have the following rights under data protection law. These rights are not absolute and would depend on our purposes for processing. Some of them apply in limited circumstances:
The following rights always apply:
Right of access – you have the right to request copies of the personal data we hold about you. You always have this right.
Right to rectification – you can ask us to amend any inaccurate information, or to complete any information as required. You always have this right.
Right to be informed – you have the right to be informed about why we are collecting your personal data and the purposes for which we will use it for. This privacy notice provides the transparency around our processing, and you always have this right.
The following rights apply in certain circumstances:
Right to erasure – you have the right to request that we erase your personal data in certain circumstances.
Right to restrict processing – you have the right to ask us to put a temporary hold on the processing of your personal data. This is likely to apply where you have made another request and we need to investigate.
Right to object – You have the right to object to processing where we process it under the basis of legitimate interest. We will balance your objection against our own legitimate interest and determine if our interests would override your interests.
Right to data portability – You have the right to request that we provide you with a portable copy of your personal data, that can be reused by another organisation. This only applies to information that you have provided to us and is unlikely to apply for our recruitment processing.
Rights in relation to automated decision making (including profiling) – You have the right to contest any decision taken by solely automated means (where there is no human involvement). We do not take any automated decisions in our recruitment process, so this right is unlikely to apply.
How to contact us
If you would like further information on how your personal data is processed, or anything mentioned in this notice please contact our Data Protection Officer at: DPO@nationalwealthfund.org.uk.
If you have any queries related to your application or about our recruitment process in general, please contact recruitment@nationalwealthfund.org.uk.
If you are not satisfied with our response, you have a right to make a complaint to the Information Commissioner’s Office. They can be contacted at:
The Information Commissioner's Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF