Introduction and applicability
From 25 May 2018, this policy will apply to any job applicant applying for a role at Cogress.
As part of any recruitment process, Cogress collects and processes personal data relating to job applicants. The Firm is committed to being transparent about how it collects and uses your personal data, and to meeting its data protection obligations.
What information do we collect?
During the recruitment process, we collect a range of information about you, such as:
- Your CV, any cover letter and e-mail you may send to us together with your job application.
- Your name, address and contact details (i.e. email address, phone numbers);
- Details of your qualifications, skills, experience and employment history;
- Information about your current level of remuneration, including benefit entitlements;
- Whether or not you have a disability for which the Firm needs to make reasonable adjustments during the recruitment process;
- Information about your entitlement to work in the UK.
- Notes we may take during the interview process.
We may collect this information in a variety of ways – e.g. data might be contained in application forms, CV or resume, or collected through interviews or other forms of assessment.
We may also collect personal data about you from third parties, such as references supplied by former employers or recruitment agencies. We will seek information such as references from third parties and proof of address and identity only once we make a job offer to you and will inform you that we are doing so.
Personal data about you will be stored in a range of different places, including our online HR management systems and on other IT systems (e.g. email).
Why does Cogress process personal data?
We need to process data to take steps at your request prior to entering into an employment contract with you. In some cases, we need to process data to ensure that we are complying with our legal obligations (e.g. it is mandatory to check a successful applicant’s eligibility to work in the UK before employment starts).
Cogress has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
Cogress may process special categories of data, such as information about ethnic origin, to monitor recruitment statistics. The Firm may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. The Firm process such information to carry out its obligations and exercise specific rights in relation to employment.
If a job applicant application is unsuccessful, Cogress may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
If a job applicant’s application is successful and he/she becomes an employee of Cogress, he/she will be provided with the GDPR Privacy Notice for Employees and the relevant Human Resources Manual.
Who has access to data?
Your information may be shared internally for the purposes of the recruitment exercise (e.g. interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles).
We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks.
Transfers of the personal data to any third countries
We may transfer and share, as applicable, your personal data, or part of, with third parties (e.g. a data processor (“data processor” is a person, or organisation, which processes personal data for the data controller), or entities that make up our international network) located outside of the European Economic Area (“EEA”). We will only transfer, or share, your personal data to such parties where:
- The European Commission has decided that the third country in question ensures an adequate level of protection, for the rights and freedoms of data subjects in relation to the processing of personal data; and
- There is a GDPR complaint contract/agreement between Cogress and the third party in respect of such transfer.
By providing us with your personal data, you are agreeing to the transfer, storing, and/or processing of your personal data as explained above. Please contact us with any questions you may have regarding such transfers.
How does Cogress protect data?
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
For how long do we keep the data for?
If your application for employment is unsuccessful, Cogress will hold your data on file for 6 months after the end of the relevant recruitment process.
If you agree to allow us to keep your personal data on file, we will hold your data on file for a further 6 months for consideration for future employment opportunities. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed. You will be asked when you submit your CV whether you give us consent to hold your details for the full 12 months in order to be considered for other positions or not.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper based) and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
The GDPR provides the following rights for individuals:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
If you would like to request to exercise any of your rights, please contact [email protected].
If you believe that Cogress has not complied with your data protection rights, you have the right to complain to the Information Commissioner’s Office (“ICO”) (www.ico.org.uk).
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to Cogress during the recruitment process. However, please keep in mind that if you do not provide the information, we may not be able to process your application properly, or at all.
This policy was last updated on 24 May 2018.