The kind of information we hold about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.We will collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
- Date of birth
- Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
- As part of the recruitment process we may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions as part of equal opportunities reporting obligations
- Information about your health, including any medical condition, health and sickness records
- Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about you through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. In addition we may from time to time collect additional personal information from you to enable us to meet our legal obligations or our operational requirements. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4. Where we need to protect your interests (or someone else’s interests).
Situations in which we will use your personal information
In some cases we may use your personal information to pursue legitimate interests of our own or those of our business partners or customers, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below;
- Making a decision about your recruitment or appointment.
- Determining the terms on which you work for us.
- Checking you are legally entitled to work in the country in which you have applied for a position.
- Assessing qualifications for a particular job or task, including decisions about promotions.
- Gathering evidence for possible grievance or disciplinary hearings.
- Making decisions about your continued employment or engagement.
- Making arrangements for the termination of our working relationship.
- Education, training and development requirements.
- Ascertaining your fitness to work.
- Equal opportunities monitoring.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Information about criminal convictions
We envisage that we will hold information about criminal convictions. We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process, this information will only be retained for as long as it is needed to assist in making a decision on recruitment and will be securely deleted thereafter.
Automated decision-making
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents and contractors who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from Ebbo’s Head of Data Privacy at info@ebbotigers.com .
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach which may adversely affect you where we are legally required to do so.
Data retention
How long will you use my information for?
The information you provide will be kept on file by Ebbo in our CV management system for a period of six (6) months from the date of submission. If after that period no job has been matched to the information you provided, your personal information will be deleted from our database.
If you are contacted directly by Ebbo’s Human Resources department after the date of submission of your CV, Ebbo will be bound by the relevant legislation regarding the retention of your CV on its database during the period when it is considering hiring or employing you and if you are employed, during your employment period. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Your rights in connection with personal information
In some circumstances the General Data Protection Regulation (GDPR) may grant you certain rights in relation to your data. These rights are detailed below along with how we will respond in circumstances where these rights apply:
- Request access to your personal information (commonly known as a “data subject access request”). In circumstances where these rights apply you will be able to request a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. In circumstances where these rights apply you will be entitled to request that we correct any incomplete or inaccurate information we hold about you.
- Request erasure of your personal information. In circumstances where these rights apply you will be entitled to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You may also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information. In certain circumstances you may be entitled to object to us processing your personal information.
- Request the restriction of processing of your personal information. In circumstances where these rights apply you may be entitled to request that we restrict the processing of your personal information.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Ebbo’s Head of Data Privacy at info@ebbotigers.com .
What we may need from you
We may need to request specific information from you to help us to confirm your identity and ensure your right to access the information (or to exercise any of your 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.