Recruitment Privacy Notice

 
 
  1. Introduction and data controller

We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. It is important that you read all of this Notice carefully as it sets out how Healthware Group ("Healthware Group", "we" or "us") handles your personal information when you apply for a job or other role with us and the rights you have in connection with that information. The term "applicants" is used in this Notice to refer to anyone who applies for a job role, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).

The Healthware Group legal entity with whom you are applying to join is primarily responsible for determining the purposes and means of the processing of your personal information as data controller.

If you are in any doubt, or have any comments or questions about this Notice, please contact us using the contact details set out at Section 8 below.

  1. Types of personal information we collect when you apply

We collect personal information about you when you apply for a job with us and during the recruitment process. How far you progress in the recruitment process will depend on the level of data that we collect. Your personal information will be collected either directly from you or indirectly from third parties.

Information that you provide directly

We collect personal information directly from you when you choose to provide us with this information online and any subsequent communications between ourselves whether online or offline throughout the recruitment process.

Information that we collect automatically

You can visit the recruitment section of our website ("Website") and search for jobs without providing personal information. However, we do collect certain information automatically from your device when you visit our Website. For further information, please see the privacy notice that applies to the use of our Website.

Information from third parties

On occasions, Healthware Group will use recruiters, who will provide us with your personal information. Any offer we make may also be subject to the receipt of references from previous employers and other relevant background checks. We will only contact referees whose details you provide to us. We will make it clear to you [at the outset of the application process] whether checks are undertaken with the Disclosure and Barring Service.

  • The table below describes the categories of personal information we collect from and about you through our online application process [and on social media].

Personal Data Description

Source

Contact Information such as your title, name, phone number, date of birth, home address and personal email address.

 Directly from you

Job Application InformationProfessional History, Educational History and Qualifications such as position applied for, previous roles, job description, responsibilities and assignments, years of service, qualifications and experience, compensation and salary data as volunteered by the candidate, eligibility for and participation in benefit schemes and other information contained in your CV.

 Directly from you

[Results of Reference Checks and Screening such as verification of education and employment history.]

 Third parties

Nationality, Citizenship and Right to Work Information such as country of birth, government identification documents (including passports and residency permits) and, where relevant, visa information.

 Directly from you online and offline

Interview Information such as comments and notes made by interviewers or other Healthware Group employees in connection with your application.

 Directly from you offline

Any other data provided by you in the course of the application process such as electronic communications with you in relation to the application process.

 Directly from you online

Equal Opportunity Information such as information relating to your gender, race, ethnicity, and veteran status.

 Directly from you online

 

Special Category Personal Information

As a general rule, during the recruitment process, we try not to collect or process any of the following: information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health/sex life ("Special Category Personal Information"), unless authorised by law or where necessary to comply with applicable laws.

In some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Special Category Personal Information [(information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health/sex life)] for legitimate recruitment-related purposes: for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations; or information about your physical or mental condition to consider accommodations for the recruitment process and/or subsequent job role. You may provide, on a voluntary basis, other Special Category Personal Information during the recruitment process.

  1. How we use your personal information (our purposes) and our legal basis for processing it

We collect and use this personal information primarily for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying our reference checks or background checks (where applicable) and to generally manage the hiring process and communicate with you about it.

If you are accepted for a role at Healthware Group, the information collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with our Employee Privacy Notice.

If you are not successful, we may still keep your application (within the statutory timeline) to allow us to consider you for other suitable openings within Healthware Group in the future unless you request that we delete your application.  

Depending on our purpose for collecting your information, we rely on one of the following legal bases:

  • Contract - we require certain personal information in order to take steps prior to entering into an employment contract with you;
  • Consent – in certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal information, in which case you can voluntarily choose to give or deny your consent without any negative consequences to you;
  • Legitimate interests – we may use or disclose your personal information for the legitimate business interests of Healthware Group but only where we are confident that your privacy rights will remain appropriately protected. If we rely on our legitimate interests in relation to your personal information, these interests will normally be to manage job applications and offers for positions with Healthware Group; communicate with applicants; and review and improve our recruitment process; or
  • Legal obligation – there may be instances where we must process and retain your personal information to comply with laws or to fulfil certain legal obligations including in response to lawful requests by public authorities (such as for tax, immigration, health and safety, national security or law enforcement purposes); or to establish, exercise or defend against potential, threatened or actual legal claims.

The following table provides more details on our purposes for processing your personal information and the related legal bases. The legal basis under which your personal information is processed will depend on the data concerned and the specific context in which we collect it.

Where we require your data to pursue our legitimate interests, it will be in a way which is reasonable for you to expect as part of the running of our organisation and which does not materially affect your rights and freedoms. We have identified below what our legitimate interests are.

 

Equal Opportunity Information, such as information relating to your gender, race, ethnicity, and veteran status.

Category of Personal Data

How we use it (purposes)

Legal basis for the Processing

Contact Information such as your title, name, phone number, date of birth, home address and personal e-mail address.

We use this information to open and maintain applicant records.

The Processing is necessary for our legitimate interests, namely managing job applications for positions at Healthware Group.

We use this information to communicate with you as part of the recruitment process.

The Processing is necessary for our legitimate interests, namely communicating with Applicants and managing job applications for positions with at Healthware Group.

We use this information to conduct identity and background checks with respect to your education and employment history.

We will use your personal information in this way to the extent you have given us your consent to do so.

Job Application Information, Professional History, Educational History and Qualifications such as position applied for, previous roles, job description, responsibilities and assignments, years of service, qualifications and experience, compensation and salary data as volunteer by the candidate, eligibility for and participation in benefit schemes and other information contained in your CV.

We use this information to Process and assess your application, including assessing your suitability for a role.

The Processing is necessary in order to take steps prior to entering into a contract with you.

We use this information to calculate proposed salary and assessing eligibility for certain benefits.

The Processing is necessary in order to take steps prior to entering into a contract with you.

We use this information to monitor and improve our application process.

The Processing is necessary for our legitimate interests, namely reviewing and updating our application process.

Results of Reference Checks and Screening such as verification of education and employment history.

We use this information to Process and assess your application, including assessing your suitability for a role.

The Processing, where needed, allow us to take steps prior to entering into a contract with you.

Nationality, Citizenship and Right to Work Information such as country of birth, government identification documents (including passports and residency permits) and, where relevant, visa information.

We use this information to determine your eligibility to work.

The Processing is necessary for compliance with a legal obligation to which we are subject.

We use this information to fulfil our obligations to relevant government authorities.

The Processing is necessary for compliance with a legal obligation to which we are subject.

Interview Information such as comments and notes made by interviewers or other Healthware Group employees in connection with your application.

We use this information to Process and assess your application, including assessing your suitability for a role.

The Processing is necessary in order to take steps prior to entering into a contract with you.

We use this information to calculate proposed salary and assess eligibility for certain benefits.

The Processing is necessary in order to take steps prior to entering into a contract with you.

We use this information to monitor and improve our application process.

The Processing is necessary for our legitimate interests, namely assessing and managing applications for positions at Healthware Group.

Any other data provided by you in the course of the application process, including electronic communications with you in relation to the application process.

We use this information to Process and assess your application, including assessing your suitability for a role.

The Processing is necessary in order to take steps prior to entering into a contract with you.

We use this information to respond to your enquiries and to monitor and improve our application process.

The Processing is necessary for our legitimate interests, namely managing applications and improving the application process.

We will anonymize this information where possible. We will aggregate this information to understand, monitor and improve our application process in line with our diversity and inclusion strategy.

We will only Process this personal data to the extent that you have given us your explicit consent to do so.

 

  1. Who we share your personal information with and transfers abroad

We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of the information is maintained.

Transfers to other group companies

We will share your personal information with other members of our group of companies in order to administer our recruitment processes and store data.

Transfers to third party service providers

We may make certain personal information available to third parties who provide services relating to the recruitment process to us, including:

  • recruitment or executive search agencies involved in your recruitment;
  • background checking or other screening providers and relevant local criminal records checking agencies;
  • data storage, shared services and recruitment platform providers, IT developers and support providers and providers of hosting services in relation to our careers website;
  • third parties who provide support and advice including in relation to legal, financial / audit, management consultancy, insurance, health and safety, security and intel and whistleblowing / reporting issues.
  1. Data retention periods

Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally this means your personal information will be retained:

  • in accordance with the retention periods set out in the Healthware Group Employee Privacy Notice or
  • for a period of 24 months after confirmation that your application was unsuccessful unless you request that we delete your application.
  1. Your data privacy rights

You may exercise the rights available to you under applicable data protection laws as follows:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below.
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

  1. Contact details

Please address any questions or requests relating to this Notice to HR department or local Data Protection Officer (DPO) if you have one.

A list of our current DPOs and their contact details can be accessed here.