Recruitment Privacy Policy

POLICY DERIVED BY H.R. & I.T SUB GROUP

This policy should be read in conjunction with the Hospice’s Privacy Policy available by visiting www.springhill.org.uk

1 - Introduction

Springhill Hospice is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. If you are applying for work with us this notice makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

2 - Responsibilities

The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to Springhill Hospice collecting/processing their personal data.

All employees/staff of Springhill Hospice who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secure.

3 - Recruitment Privacy Notice

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

3.1 - What information does Springhill Hospice collect?

Springhill Hospice may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport, driving licence or other identity documents, or collected through interviews or other forms of assessment.

Springhill Hospice may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks (from the Disclosure and Barring Service – DBS). Other than employment agencies, Springhill Hospice will only seek personal information from third parties during the recruitment process once an offer of employment has been made and will inform you that the hospice is doing so.

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).

The following table provides examples of the data we may collect, use, store and transfer. It also explains the purposes for which we use different categories of personal data, and the lawful basis or bases which we believe applies to those uses. Please note, the lists are provided as an example and are not exhaustive, they may change from time to time:

To help us process your application to work with us as an employee or volunteer:

We can collect your data from a number of sources. This will depend on how you have submitted your interest in working or volunteering with us. The source of your data can be you, an online job/volunteering website that you have signed up to, a recruitment consultant or referees that you have supplied for your application. We will keep records of your application and personal data, whether successful or unsuccessful, in paper and electronic forms. Details of the data we process include, but are not limited to:

Name and contact details e.g. address, telephone number and e-mail
Education and employment history
Evidence of qualifications
Professional memberships
References and their contact details

Springhill Hospice may also collect, use and process the following special categories of your personal information during the recruitment process:

whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
information about your racial or ethnic origin, religious or philosophical beliefs and sexual orientation and
information about criminal convictions and offences

If your application is unsuccessful, a copy of your application and supporting data will be retained for 6 months. If your application is successful, a copy of your application, supporting data and interview notes will be included in your HR P File.

At the time of job offer, we will also collect further data from you and hold it on your HR P File, for example:

Forms of identification
Proof of eligibility to work in the UK
Disclosure and Barring Service Checks
Occupational Health Assessments or other health/disability assessments
Driving licence, vehicle registration and insurance documents
Equal Opportunities data
Emergency contacts
Bank details
National Insurance / Professional PIN numbers
Pension details

At the start of your employment/service you will be issued with the Hospice’s Staff and Volunteer Privacy Notice which details how we will process your data as an employee/volunteer.

We use your personal data for the following purposes:

Your data is used for administration, management and organisational purposes, for example:

To keep a record of your application, including screening and interviews to assess your suitability for the role and right to work in the UK;
To manage the recruitment process and decide to whom to offer a job;
To be able to contact you throughout your application and term of employment/service;
To send your contract and other necessary correspondence;
To ensure effective HR, personnel management and business administration
To protect our Hospice, patients, staff and visitors from crime and mis-conduct;
To monitor equal opportunities, and
To conduct surveys.

We also need to process your data to ensure that we are complying with the statutory and/or regulatory requirements, for example:

For proof of eligibility to work in the UK;
To ensure the safety and security of our patients, staff/volunteers and the organisation, as we are working with vulnerable individuals; and
For compliance with the Equality Act 2010 and to make reasonable adjustments for disabled job applicants and with other disability discrimination obligations.

We may also share your data with other organisations when we are required to do so by law, for example:

If we are sent a request from the Police under the Crime and Disorder Act 1998;
If there is a need to protect and safeguard vulnerable children and adults;
If there is a public health need such as preventing the spread of infectious diseases; or
If we receive a formal order from a court acting in their judiciary capacity

How we process your data lawfully

Contract – to provide you with an employment contract.
For the assessment of your working capacity and occupational health.
Consent – to process your personal data when you apply to/and volunteer for Springhill Hospice or when you complete our equal opportunities forms to help us monitor compliance with the Equality Act 2010, also to consent to take part in research. You have the right to withdraw consent at any time and we will stop processing your data in an identifiable format.
Legal Obligation –

To ensure all staff are eligible to work in the UK in line with the Home Office Code of Practice on Preventing Illegal Working 2019
To ensure compliance with the Safeguarding Vulnerable Groups Act 2006
To ensure compliance with the Income Tax Act 2007
To ensure compliance with the Companies Act 2006
To ensure compliance with the Equality Act 2010
To manage your personal records in line with the NHSX – Records Management Code of Practice and the Data Protection Act 2018 and UK General Data Protection Regulation.
Legitimate Interest – to ask if you’d like to take part in market research.

3.2 - Why and how do Springhill Hospice process your personal data?

Where the Hospice has a legal basis for processing your personal information it will do so :

To process data to take steps at your request prior to entering into a contract with you. The hospice may also need to process your data to enter into a contract with you.
To process data to ensure that the hospice is complying with our legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.
Where it is necessary for our legitimate interests, and your interests, or fundamental rights and freedoms, do not override our interests

Springhill Hospice has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Springhill Hospice to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. Springhill Hospice may also need to process data from job applicants to respond to and defend against legal claims.

Springhill Hospice may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. Springhill Hospice processes such information to carry out its obligations and exercise specific rights in relation to employment.

For some roles, Springhill Hospice is obliged to seek information about criminal convictions and offences. Where the hospice seeks this information, it does so because it is necessary to carry out our obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, Springhill Hospice may keep your personal data on file in case there are future employment opportunities for which you may be suited. Springhill Hospice will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Please note that the hospice may process your personal information without your consent, in compliance with these rules, where this is required or permitted by law.

Sensitive personal information

Springhill Hospice will only collect and use your sensitive personal information, which includes special categories of personal information and information about criminal convictions and offences when the law allows us to do so. This data is processed so that the hospice can perform or exercise our obligations or rights under employment law and in line with our data protection policy.

The Hospice may also process information about your health and information about any criminal convictions and offences where the hospice has your explicit written consent. In this case, the Hospice will first provide you with full details of the personal information requested and the reason it is needed, so that you can properly consider whether you wish to consent or not. It is entirely your choice whether to consent and your consent can be withdrawn at any time.

The purposes for which Springhill Hospice processes health information and information about any criminal convictions and offences, is to:

Assess your suitability for employment
Comply with statutory and/or regulatory requirements and obligations (for example, carrying out criminal record checks)
Comply with the duty to make reasonable adjustments for disabled job applicants and with other disability discrimination obligations
Ensure compliance with your statutory rights
Ascertain your fitness to work
Ensure effective HR, personnel management and business administration
Monitor equal opportunities

Springhill Hospice processes information about other special categories of personal information (for example, racial or ethnic origin, religious or philosophical beliefs and sexual orientation) purely for the purpose of equal opportunities monitoring in recruitment and in line with our data protection policy. The personal information used for these purposes is anonymised and is collected with your explicit consent, which can be withdrawn at any time. It is entirely your choice whether to provide such personal information.

4 - Who has access to your data?

Your personal information may be shared internally for the purposes of the recruitment exercise. 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.

Springhill Hospice will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Springhill Hospice 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.

4.1 - How does Springhill Hospice protect your data?

Springhill Hospice takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. At Springhill Hospice we take the security of personal data and privacy seriously. For example: If you apply for a job with us your personal information may be shared internally for the purposes of the recruitment exercise. 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.

Further detail is available in the Springhill Hospice Privacy Policy under point 14.

5 - How long does Springhill Hospice keep data?

If your application for employment is unsuccessful, Springhill Hospice will hold your data on file for six months after the end of the relevant recruitment process, in accordance with our retention policy. If you agree to allow Springhill Hospice to keep your personal data on file, your data will be held on file for a further 6 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 you in the Staff and Volunteer Privacy Notice.

6 - Your rights

You have the following rights regarding your personal data:

Access: Request access to your data.

Correction: Request correction of inaccurate or incomplete data.

Erasure: Request deletion of your data under certain conditions.

Restriction: Request restriction of data processing.

Objection: Object to processing based on legitimate interests.

Data portability: Request transfer of your data to another organisation.

If you would like to exercise any of these rights please speak to the Data Protection Officer.

If you believe that Springhill Hospice have not complied with your data protection rights, you can complain to the Information Commissioner’s Office.

7 - What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Springhill Hospice during the recruitment process. However, if you do not provide the information when requested, the hospice: may not be able to process your application properly or at all; may not be able to enter into a contract with you; or may be prevented from complying with its legal obligations. You may also be unable to exercise your statutory rights.

8 - Automated decision-making

Recruitment processes are not based solely on automated decision-making.

9 - Changes to this Recruitment Privacy Notice

Privacy laws and practices are constantly developing and at Springhill Hospice aim to meet high standards. The hospice’s policies and procedures are, therefore, under continual review. The hospice may, from time to time, amend or update security and privacy policies and notices.

This notice was last updated January 2025.

How to contact us

If you have any questions regarding the Recruitment Privacy Notice please contact:

Data Protection Officer

Springhill Hospice

Broad Lane

OL16 4PZ

Tel: 01706 649920

Helping you

Helping us

POLICY DERIVED BY H.R. & I.T SUB GROUP

Get in touch

We are happy to answer any questions you have about our privacy policy