Data controller:

Head of Talent Acquisition
Claudia Sneddon
claudia.sneddon@expleogroup.com

Data protection officer:
Juan Manuel Lopez
juan-manuel.lopez@expleogroup.com

As part of any recruitment process, the organisation collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does the organisation collect?

The organisation collects a range of information about you. This includes:

  • personal details including your name, address, email address, phone numbers
  • photograph (if provided on your application)
  • information included on your CV including references, education history and employment history
  • documentation relating to your right to work
  • current and previous job titles, job descriptions
  • details of your criminal record

How do we collect your data?

The organisation collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies. Where this is necessary, we will inform you and seek your consent to proceed.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why does the organisation process personal data?

We use your data to process your application and assess your suitability for employment with us. This includes:

  • The review of your application, CV and / or any supporting information
  • communicating with you regarding the status or outcome of your application
  • communicating with you regarding further opportunities (where appropriate and with your consent)
  • conducting reference checks (where appropriate and with your consent)
  • conducting criminal record checks (where appropriate and with your consent)

We will only use your data where we are permitted by law, e.g. fulfilling a legal obligation,  because we have a legitimate business interest (in line with ICO’s guidance) or where we have your consent to do so.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment process. This includes members of the HR and recruitment team, 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.

The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

Your data may be transferred outside the European Economic Area (EEA) to process as we have Shared Service Teams in other parts of the Expleo organisation. All the necessary internal processing policies are in place to support this.

How does the organisation protect data?

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.

Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

For how long does the organisation keep data?

If your application for employment is unsuccessful, the organisation will hold your data on file for a maximum of 12 months or less after the end of the relevant recruitment process. If you agree to allow the organisation to keep your personal data on file in a talent pool, the organisation will hold your data on file for a further maximum period of 12 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.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to your employment contract.

Your rights

The law on data protection gives you certain rights in relation to the data we hold on you. These are:

  • the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice.
  • the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request.
  • the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it.
  • the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
  • the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
  • the right to portability. You may transfer the data that we hold on you for your own purposes.
  • the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests.
  • the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent for use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so. 

You can make a subject access request by contacting the Head of Talent Acquisition at Expleo.

If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all. If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the relevant country and satisfactory references.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.