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Job Applicant Privacy Notice

5th April 2018

Data controller: Cogentia Healthcare Consulting Ltd (Cogentia)

Data protection contact: Charis Beynon

As part of any recruitment process, we collect and process personal data relating to job applicants. Cogentia is committed to being transparent about how we collect and use that data and in meeting our data protection obligations.

What information does Cogentia collect?

Cogentia collects and processes a range of information about you. This includes:

  • your name, address and contact details, including email addresses and telephone numbers, date of birth and gender;
  • 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 Cogentia needs to make reasonable adjustments during the recruitment process;
  • information about your entitlement to work in the UK; and
  • Occasionally, we may collect information regarding criminal convictions.

Cogentia may collect this information in a variety of ways. For example, data might be collected through application forms, CVs or resumes, or collected through interviews, meetings or other assessments.

In some cases, Cogentia may collect personal data about you from third parties, for example  references supplied by former employers, information from employment background check providers, or information from recruitment agencies.

Data will be stored in a range of different locations, including in your application file, in Cogentia’s HR management systems and in other IT systems (including Cogentia’s email system).

Why does Cogentia process personal data?

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

In some cases, we need to process data to ensure that we are 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.

Cogentia 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 us to manage the 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 respond to and defend against legal claims.

Cogentia 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 our obligations and exercise specific rights in relation to employment.

We will not use your data for any purpose other for recruitment.

Who has access to data?

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

The organisation will not share your data with third parties, unless required to obtain references for you or for employment background check providers to obtain necessary background checks.

Your data may be transferred to countries outside the European Economic Area (EEA). When this occurs it is on the basis of relevant safeguards permitted by GDPR e.g. declaration of adequacy, binding corporate rules or other safeguards.

How does Cogentia protect data?

Cogentia takes the security of your data seriously. We have internal policies and controls in place to protect your data, so that it is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.

For how long does Cogentia keep data?

If your application for employment is unsuccessful, Cogentia will hold your data on file for 6 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.

Your rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require Cogentia to change incorrect or incomplete data;
  • require Cogentia to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
  • object to the processing of your data where Cogentia is relying on our legitimate interests as the legal ground for processing;

If you would like to exercise any of these rights, please contact Cogentia’s Data Protection contact.

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

What if you do not provide personal data?

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

Automated decision-making

Cogentia’s employment decisions are not based on automated decision-making or profiling.