Personal data we collect and use
As part of any recruitment process, we collect a range of information about you, either provided by you or through recruitment agents acting on your behalf. This includes:
- your name and contact details, including your residential address, telephone numbers, e-mail address, date of birth, and title;
- details of your qualifications, skills, experience, education and employment history, including start and end dates with previous employers, (including details of any periods where you were not working), references, Professional Memberships and other interests.
- information about your current level of remuneration, including any benefit entitlements;
- whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK;
- where the role involves driving, details of your driving licence;
- diversity and inclusion monitoring information, including information about your ethnic origin, date of birth, marital status, sexual orientation, health (including mental health) religion or belief, and/or political affiliations; and
- any other personal data you volunteer as part of the application process.
We collect this information in a variety of different ways. For example, your personal data may be contained in any application forms provided, or in your CV or resume, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment including online tests.
You are under no statutory or contractual obligation to provide any requested personal data to us during the recruitment process. However, if you do not provide the requested information, we may not be able to process your application properly or at all.
Certain information, such as contact details, your right to work in the UK and payment details, have to be provided once an offer of employment is made to enable us to enter into a contract of employment with you. If refuse or are unable to provide this information to us, we will be unable to confirm your offer of employment.
How we use your personal data
We process your personal data to take steps at your request prior to entering into a contract with you. We also process your data, if your application is successful, to enter into an employment contract with you and to manage your employment with us.
In some cases, we need to process your personal data to ensure that we are complying with legal obligations imposed on us. For example, we are required to check a successful applicant's eligibility to work in the UK before their employment with us starts.
We have 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 our 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 allow us to investigate complaints and/or to respond to and where appropriate, defend legal claims.
We process health information, where volunteered by you, if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our legal obligations in ensuring that we do not directly or indirectly discriminate against any individuals on the basis of their health. If you do not provide us with such health information, we are unable to make any reasonable adjustments to accommodate you.
Where we process sensitive data such as information about ethnic origin, sexual orientation, physical or mental health or religion or belief as part of the application process, this is done for the basis that there is a substantial public interest in ensuring that we are not intentionally or indirectly discriminating against any groups or individuals. You are not required to provide us with information for this purpose during the application process and there will be no consequences for any applicant who elects not to provide it.
For some roles, we are obliged to seek information about unspent criminal convictions and offences. Where we seek this information, we do so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
When you register on our recruitment system, if you agree, we will keep your personal data on file in case there are future employment opportunities for which you may be suited for a period of 12-months to enable ease of re-application. You will receive an email from us 12-months after the original date that you have set up job email alerts to give consent that you still wish to receive them. You can remove your consent at any time.
Who we share your personal data with
Your personal data will be shared internally for the purposes of managing the recruitment exercise. This includes sharing your information with members of our HR and HR Shared Service teams, interviewers involved in the recruitment process and managers in the business area with a vacancy. In addition, your personal data may be accessed, where necessary, by our IT staff where e.g. where they are maintaining our HR software.
We will not normally 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 your former employers or other referees provided by you, to obtain references for you, employment background check providers to obtain necessary background checks and for certain job roles, the Disclosure and Barring Service to obtain necessary criminal records checks.
Who we may receive your personal data from
CEC will also collect personal data about you from third parties, such as:-
- when your details were provided by a recruitment agency.
- references supplied by former employers.
- information from employment background check providers and for specified roles.
- information about any criminal convictions or offences (where this is relevant to the requirements of the role you are applying for and where the information has been made public or it is necessary to protect the interests of you or someone else).
- fraud prevention checks and credit references may also be made dependent on job role.
We will only request your personal data from third parties only once a job offer to you has been made and will inform you that it is doing so.
How long we keep your personal data
We will normally hold your data on file for 12 months after the end of the relevant recruitment process. If you agree to allow us to keep your personal data on file, with the purpose of enabling ease of future applications, you will receive an email every 12 months asking for your consent to retain for this purpose for a further 12 months. If you do not consent to the continuing processing of your personal data, then your personal data will be deleted.
If your application for employment is successful, any personal data gathered during the recruitment process will be transferred to your personnel file contained within a range of HR Systems and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice issued alongside your contract of employment.
Some of our recruitment processes are based solely on automated decision-making. Certain vacancies such as Customer Services Assistant roles that attract a large number of applicants may include a question set that requires specific responses to allow the applicant to move to the next stage of recruitment.
You have the following rights in respect of any automated decision making process:-
- the right not to be subject to any decisions wholly made on the basis of automated processing; and/or
the right to request a review of any such decision, to be undertaken by a human. You are also entitled to present any additional evidence or arguments to be considered by the human undertaking the review.