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COLLECTION AND RETENTION OF DATA

Collection of data

The Company will collect personal information about applicants through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. The Company may sometimes collect additional information from third parties including former employers.

From time to time, the Company may collect additional personal information from an applicant. If the Company needs to obtain additional personal information this policy will be updated or applicants will receive a separate privacy notice setting out the purpose and lawful basis for processing the data. 


Retention of data

The Company will only retain applicants’ personal information for as long as necessary to fulfil the purposes it was collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of personal information are set out in the table of applicant data appended to this policy. 

When determining the appropriate retention period for personal data, the Company will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which the personal data is processed, whether the Company can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances the Company may anonymise personal information so that it can no longer be associated with individual applicants, in which case the Company may use such information without further notice to applicants. After the data retention period has expired, the Company will securely destroy applicants’ personal information.


DATA SECURITY AND SHARING

Data security

The Company has put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  


Data sharing

The Company may share personal information with third parties. The Company requires third parties to respect the security of applicant data and to treat it in accordance with the law. The Company may also need to share personal information with a regulator or to otherwise comply with the law.

The Company may also share applicant data with third-party service providers where it is necessary to administer the working relationship with applicants or where the Company has a legitimate interest in doing so. The following activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services.


STAFF MEMBER RIGHTS AND OBLIGATIONS

Accuracy of data

The Company will conduct regular reviews of the information held by it to ensure the relevancy of the information it holds. Applicants are under a duty to inform the Company of any changes to their current circumstances. Where an Applicant has concerns regarding the accuracy of personal data held by the Company, the Applicant should contact the HR Team to request an amendment to the data.

 

Applicant rights

Under certain circumstances, applicants have the right to:

Request access to personal information (commonly known as a “data subject access request”).

Request erasure of personal information. 

Object to processing of personal information where the Company is relying on a legitimate interest (or those of a third party) to lawfully process it.

Request the restriction of processing of personal information. 

Request the transfer of personal information to another party.

If an applicant wishes to make a request on any of the above grounds, they should contact the HR Team in writing. Please note that, depending on the nature of the request, the Company may have good grounds for refusing to comply. If that is the case, the applicant will be given an explanation by the Company. 

 

Data subject access requests

Applicants will not normally have to pay a fee to access personal information (or to exercise any of the other rights). However, the Company may charge a reasonable fee if the request for access is clearly unfounded or excessive. Alternatively, the Company may refuse to comply with the request in such circumstances.

The Company may need to request specific information from the applicant to help confirm their identity and ensure the right to access the information (or to exercise any of the other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.


COMPLIANCE WITH THIS POLICY

The Company’s responsibility for compliance

The Company has appointed a data protection officer (DPO) who is tasked with overseeing compliance with this policy. If applicants have any questions about this policy or how the Company handles personal information, they should contact the HR Director or the DPO. Applicants have the right to make a complaint at any time to the appropriate supervisory authority for data protection issues:

Guernsey – The Office of the Data Protection Commissioner

Jersey – Office of the Information Commissioner

UK - Information Commissioner’s Office (ICO)


Data security breaches

The Company has put in place procedures to deal with any data security breach and will notify applicants and any applicable regulator of a suspected breach where legally required to do so. Details of these measures are available upon request.

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