CFP Privacy Notice – Job Applicants

Westcotts Financial Management Limited’s Privacy Notice – Job Applicants

Data Controller

Westcotts Financial Management Limited

26-28 Southernhay East
Exeter EX1 1NS

Any reference to ‘Westcotts Financial Management Limited’ or the ‘Firm’ as Data Controller within this privacy notice also refers to the wider firm which includes ‘Westcotts Chartered Accountants’, ‘Westcotts Business Recovery and Insolvency LLP’, ‘Westcotts Financial Management Limited’ trading as ‘Westcotts Chartered Financial Planners’ and ‘Westcotts Secretarial Limited’.

Data Protection Officer

To enquire about any aspect of this document or your associated data protection rights please contact Westcotts’ Data Protection Officer:

Mr P Tigwell
26-28 Southernhay East Exeter
Devon EX1 1NS

Email: patrick.tigwell@westcotts.uk
All initial contact should be in writing (by post or email).

General

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

Lawful reason for processing client personal data

The Firm needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.

The Firm maintains a database of job vacancies. Upon receipt of consent from you we will provide you with periodic updates.

Westcotts Financial Management Limited acts as Controller.

In some cases, the Firm needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.

The Firm 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 the Firm to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The Firm may also need to process data from job applicants to respond to and defend against legal claims.

The Firm may process information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

Where the Firm processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

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

Categories of personal data collected by Westcotts Financial Management Limited

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

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which the Firm needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

The Firm may collect this information in a variety of ways. For example, data might be contained in application forms, CVs and covering letters, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

The Firm 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. The Firm will seek information from third parties only once a job offer to you has been made and accepted and will inform you that it 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).

Intended recipients of the personal data

Your 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/partners/directors in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

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

Retention period

Where you have provided consent to receive notification of job vacancies we will continue to communicate with you until you withdraw consent. We reserve the right to delete your data at our discretion.

If your application for employment is unsuccessful, the Firm will hold your data on file for 12 months after the end of the relevant recruitment process. At the end of that period, 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 a new privacy notice.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the Firm during the recruitment process. However, if you do not provide the information, the Firm may not be able to process your application properly or at all.

Use of Data Processors

• Recruitment agencies

The firm uses recruitment agencies to advertise or seek applicants for vacancies within Westcotts Financial Management Limited. The agents will collect information from you during the application process which they will hold in accordance with the terms of their individual privacy notice.

• E-communication

As data controller we use a third party data processor, Campaign Master UK Ltd, to deliver our e- communication for example – job application notifications. We gather statistics around email opening using industry standard technologies to help us monitor and improve our communication. For more information, please see Campaign Master’s privacy policy.

Your rights as data subject

Right of access – where Westcotts Financial Management Limited is processing or has processed your personal data you have rights as an individual to get a copy of the information that we hold about you. This is known as a subject access request.

For these to be managed effectively, subject access requests must be made in accordance with the guidance issued by the Information Commissioner’s Office (www.ico.org.uk/for-the-public/). All requests should be submitted to Westcotts’s Data Protection Officer.
Failure to submit a subject access request in this format may result in the request being rejected.

The right to rectification – you have the right to request rectification of your personal data where errors have been identified.

Any such request must be made verbally or in writing by post or via email to the Firm and a response will be issued within one month of receipt.

Please note that there may be instances where such requests cannot be fully satisfied and in such cases a full explanation will be provided within the response.

The right to erasure – you have the right to request erasure (also known as ‘the right to be forgotten’) of your personal data.

Any such request must be made verbally or in writing by post or via email to the Data Protection Officer and a response will be issued within one month of receipt.

Please note that there may be instances where such requests cannot be fully satisfied and in such cases a full explanation will be provided within the response.

Right to restriction of processing – you have the right to obtain from us a restriction of processing where one of the following applies:

a) The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data.
b) The processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead.
c) We no longer need the personal data for the purposes of processing, but you require us to retain the data for the establishment, exercise or defence of legal claims.
d) An objection to the processing of personal data has been raised by you, for a period enabling us to
consider whether your rights are overridden by our legitimate reasons to retain the data.

Right to data portability – where it is practicable to do so we will provide an active secure self-service system to provide your personal data held by us.

Where it is not practicable to provide an active self-service system, upon receipt of a ‘right of access request’ information held will be made available via a secure self-service system and direct access will be granted to you.

Where possible the data will be provided in a suitable electronic format which complies with the GDPR guidelines on data portability. Where this is not possible this will be explained.

Please note that the right to obtain access to personal data through a remotely accessed secure system should not adversely affect the rights and freedoms of others.

The right to object – you have the right to object to:

• processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
• direct marketing (including profiling); and
• processing for purposes of scientific/historical research and statistics.

Westcotts Financial Management Limited will adhere to the guidelines set by the Information Commissioner’s Office upon receipt of an objection. The objection can be made verbally or in writing to the firms marketing department or Data Protection Officer.

All processing will cease upon receipt of a relevant objection. The Data Protection Officer will issue a formal response to the objection within one month of receipt.

Automated decision making and profiling

The firm does not perform any tasks which rely solely on automated decision making or profiling.

Complaints or queries

Westcotts Financial Management Limited tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice has been drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Westcotts Financial Management Limited’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address above.

If you want to make a complaint about the way we have processed your personal information, in the first instance please contact the Data Protection Officer. If the Data Protection Officer is unable to satisfactorily deal with your complaint, or you are not satisfied with our response or believe our processing of your personal data is not in accordance with the law you can complain to the Information Commissioner.

Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

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