1.1 EdPlace Limited (“EdPlace”, the “Company”) is committed to ensuring that your privacy is protected. This privacy notice explains how we process personal data concerning Job Applicants and Candidates who apply for roles with us (“you”, “your”). It applies to current and former Job Applicants (“Job Applicants”), and current and former Candidates (“Candidates”).
1.2 This notice sets out what personal data we collect, why we collect it, how we use it and the legal basis for doing so and the procedures we have in place to protect your personal data. It is important to read this notice, together with any other privacy policy relevant to your current relationship with EdPlace, when we are processing your personal data, so that you are aware of how and why we are using your information.
1.3 If you are a resident of the United Kingdom (“UK”), the handling of your personal data will be subject to UK legislation relating to personal data, including the UK GDPR (EU GDPR as incorporated into UK law). If you are a resident of a country in the European Economic Area (“EEA”), the handling of your personal data will be subject to European Union legislation relating to personal data including the EU General Data Protection Regulation (“EU GDPR”).
| Questions about your personal information If you have any questions about this privacy notice or your information, or to exercise any of your rights as described in this notice or under applicable data protection laws, please contact the Managing Director at EdPlace, Wallace House, 4 Falcon Way, Welwyn Garden City, AL7 1TW. |
3.1 Anyone processing personal data must comply with the principles of processing personal data. We set out these principles below along with our procedures for complying with such principles:
- Lawfulness, fairness and transparency – data must be processed lawfully, fairly and in a transparent manner.
- Purpose limitation - data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- Data minimisation - data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- Accuracy - data must be accurate and, where necessary, kept up to date.
- Storage limitation - data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
- Integrity and confidentiality - data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.
4.1 We collect the personal data of Job Applicants and Candidates to operate our business and to comply with our legal and regulatory obligations as prospective employers.
4.2 We collect personal data from our candidates to assist with our recruitment processes and to monitor recruitment statistics.
4.3 We set out below a list of the categories of information we may collect from Job Applicants and Candidates. We aim to make this list as comprehensive as possible but it is not exhaustive. The information that we collect includes, but is not limited to, the following:
- Personal contact details such as name, title, home address, telephone number and email address;
- Date of birth;
- Gender;
- Marital status and dependents;
- Next of kin and emergency contact information;
- Copies of passport, driving licence and similar documents;
- Education history, training and professional experience;
- Current and past employment details;
- Immigration status and work permits;
- Languages spoken and level of proficiency;
- Other information given in your CV;
- Right to work documentation;
- References;
- Relevant disciplinary and grievance records.
5.1 Some of the personal data we collect (as described in section 4), and additional information, may be provided to us by recruitment agencies with whom you have registered an interest. Such recruitment agencies support our recruitment processes under a duty of confidentiality.
5.2 During the recruitment process we may also research information regarding your skills, experience or qualifications and comments and opinions made public on social networking sites such as LinkedIn, Facebook and Twitter.
5.3 We also receive other information about you from organisations such as credit reference agencies, fraud prevention agencies and referees.
6.1 You may also supply us with, or we may receive, sensitive personal data relating to your racial or ethnic origin, genetic and biometric data, political opinions, religious or philosophical beliefs, trade union membership or data concerning your health or data concerning your sex life or sexual orientation.
6.2 We will use this information for the purposes of defending and bringing legal claims, either performing our contractual obligations or exercising obligations or rights which are imposed or conferred on us by law in connection with our obligations as an employer including:
- Monitoring of equality of opportunity or treatment;
- Considering whether adjustments may need to be made to accommodate Job Applicants and Candidates with a disability.
6.3 We may also process data which has been made manifestly made public by you or with your explicit consent.
7.1 We also collect, store and otherwise process personal data relating to criminal convictions and offences (including the alleged commission of offences).
7.2 This data is only processed where it is necessary for the purposes of:
- The prevention or detection of an unlawful act; or
- In connection with any legal proceedings (including prospective legal proceedings); or
- Obtaining legal advice; or
- Establishing, exercising or defending legal rights.
8.1 The information about you which is obtained by us during the application process (whether obtained directly from you or from third parties) may be used by us for the following purposes:
- To consider your suitability for employment or contractor services;
- To take up your references;
- To conduct appropriate checks;
- To negotiate and communicate with you in relation to your application;
- To manage and operate our business and our Workers and Employees and for administrative purposes (including inserting personal data about you in newsletters and updates sent across the EdPlace business);
- To undertake business analysis activities;
- To comply with our legal and regulatory obligations and for other legal purposes.
8.2 Your information will not be used for other purposes without your permission, save as required by applicable law.
9.1 The legal basis for our processing of your personal data is based on the fact that you are a Job Applicant or Candidate and it is necessary for us to process your information as follows:
| Purposes for which we will process the information | Legal Basis for the processing |
|---|---|
| - to consider your application in line with our recruitment purposes; | - It is in our legitimate interests to recruit employees, workers and contractors and to select the best candidates. We consider this to be necessary for our legitimate interests and will not be prejudicial or detrimental to you. |
| - to carry out background and reference checks, where applicable; | - It is in our legitimate interests to assess the suitability of candidates. We consider this to be proportionate and will not be detrimental to you |
| - for administrative purposes in connection with your employment contract or contract for services; | - It is necessary to comply with our legal obligations as a prospective employer. In addition, it is necessary to comply with our contractual obligations to our employees, workers and contractors. It is also in our legitimate interests and will not be prejudicial or detrimental to you. |
| - to undertake business analysis activities; | - It is in our legitimate interests to manage and monitor our Human Resources function. We consider this to be necessary for our legitimate interests and will not be prejudicial or detrimental to you. |
| - to comply with our legal and regulatory obligations. | - It is necessary to comply with our legal and statutory obligations as an employer and service provider. |
9.2 If you fail to provide certain information when requested, we may not be able to take your application further, or we may be prevented from complying with our legal obligations.
9.3 The legal basis for our processing of any special categories of (sensitive) personal data is based on the fact that you are a Job Applicant or Candidate and it is necessary for us to process such information to comply with our legal obligations, namely:
- for carrying out our obligations as a prospective employer; and- where relevant in relation to health data, for the assessment of the working capacity of prospective employees, workers and contractors.9.4 We also process special categories of (sensitive) personal data where necessary for the establishment, exercise or defence of legal claims.
10.1 EdPlace is part of the Supporting Education Group family of companies. We will share your personal information with our group companies as necessary to carry out the purposes for which the information was supplied or collected (i.e. to consider your application as part of our hiring process).
Please be assured that we have put in place data privacy compliance measures to ensure that those companies comply with data protection obligations and your data is kept safe and secure. In particular, we ask our group companies and partners to do the following:
- Ensure data accuracy and integrity;- Implement appropriate security measures to protect personal data;- Inform EdPlace of any data breaches or security incidents involving their students' data.10.2 For the purposes set out in section 8 above, we share information concerning Job Applicants and Candidates with:
- other authorised employees;- our professional advisors (including lawyers, accountants and auditors);- where appropriate to do so, other companies in the EdPlace group (see 10.1);- our reference checking agency.10.3 For the purposes set out in section 8 above, we may share information concerning candidates with other authorised employees.
10.4 We will also disclose personal information concerning Job Applicants and Candidates to other third parties where there is a legitimate reason to do so including for the following reasons:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;- if all or substantially all of our assets are acquired by a third party, in which case personal information held by it about its employees will be one of the transferred assets.10.5 We will also disclose your personal information to the extent we are under a duty to disclose or share your personal information in order to comply with any legal obligation.
10.6 We will also disclose your personal information to third parties who have made a request for a reference either during or following the end of your contract for services or contract of services. As it is not reasonable for us to contact you to ask for consent on every occasion that we receive a reference request, please let us know if you object to our processing your data for the purposes of providing a reference.
11.1 In connection with the administration of your references, please ask for permission from your referees before sharing their details with us. You are requested to ensure that you notify the relevant hiring manager at EdPlace of any changes to such information without undue delay.
12.1 We will take reasonable steps to try to ensure that your information is kept accurate and up-to-date. However, all Job Applicants and Candidates are requested to ensure that the hirer at EdPlace is notified of any changes to their personal information without undue delay.
12.2 Where you have notified us or we otherwise become aware of an inaccuracy in your personal information, we will take every reasonable step to ensure that the information is either erased or rectified without delay.
13.1 You have the following rights:
- to obtain access to, and copies of, the personal data that we hold about you (“subject access request”);- to require us not to send you marketing communications (if applicable);- to require us to erase your personal data (the “right to be forgotten”);- to require us to restrict our data processing activities;- to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller (“data portability”); and- to require us to correct the personal data we hold about you if it is incorrect, or to complete any data which is incomplete including by means of providing a supplementary statement (the “right to rectification”).13.2 You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on our legitimate interests. In such an event, we shall no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests or for the establishment, exercise or defence of legal claims.
13.3 If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing for such marketing.
13.4 Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.
13.5 You can exercise any of your rights as described in this notice and under data protection laws by contacting the relevant hiring manager at EdPlace.
13.6 Except as provided under applicable data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee (subject to any limits imposed by applicable law) taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.
13.7 Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.
14.1 We may store your personal data in hard copy and electronic format. We use appropriate technical and organisational safeguards to protect personal data both online and offline from unauthorised use, loss or destruction. We use physical and procedural security measures to protect information from the point of collection to the point of destruction. This includes encryption, pseudonymisation, firewalls, access controls, policies and other procedures to protect information from unauthorised access.
14.2 Only authorised personnel and third party service providers are permitted access to personal data, and that access is limited by need. We will only transfer personal data to a third party if it agrees to comply with those procedures and policies, or if it puts in place adequate measures itself.
14.3 Despite these precautions, however, EdPlace cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal data. In the event of a data breach, EdPlace has put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.
15.1 It may be necessary to transfer and store your personal data to locations outside of the UK (if you are resident in the UK) or the EEA (if you are resident in a EEA country) where we engage third party service providers whose operations are located outside of the UK or EEA in Canada, Australia and the United States of America.
15.2 Where personal data is transferred to and stored in a country outside the UK or the EU, we take steps to provide appropriate safeguards to protect your personal data, including:
- by ensuring that the country to which data is transferred has an adequate level of protection as determined by the European Commission (in the case of transfers outside the EEA) or the UK ICO (in the case of transfers outside the UK);- by ensuring that the third party service provider has provided adequate safeguards by way of standard contractual clauses approved by the European Commission (in the case of transfers outside the EEA), or the ICO (in the case of transfers outside the UK) obliging recipients to protect your personal data.15.3 If you want further information on the specific mechanism used by us when transferring your personal data out of the EEA (where you are resident in the EEA) or the UK (where you are resident in the UK), please contact us using the details set out above.
16.1 Personal data about unsuccessful candidates will be held for up to 6 months after the recruitment exercise has been completed. It will then be destroyed or deleted. We may retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data. Please refer to the EdPlace Data Retention Policy & Schedule here for the most accurate and up-to-date guidance in this area.
17.1 We do not use automated decision making to make decisions about our Job Applicants and Candidates.
18.1 We may use Recruitment Software and reporting systems to manage job applications and data about Job Applicants and Candidates, or as a method of communication.
19.1 If you have concerns about our use of your personal data, please contact the relevant hiring manager at EdPlace in the first instance.
19.2 You also have the right to complain if you are resident in the UK to the Information Commissioner’s Office (https://ico.org.uk/) or if you are a resident in the EEA to the equivalent data protection body in your country of residence.
20.1 This notice will be reviewed and, if appropriate, updated from time to time.