Last updated May 2018
1.1 Under data protection legislation, Joules is required to explain to our individuals why we collect information about you, how we intend to use that information and whether we will share your information with anyone else.
1.2 This statement applies to all prospective employees, workers and contractors.
1.3 This statement does not form part of any contract of employment or other contract to provide services. We may update this statement at any time.
1.4 It is important that you read this statement so that you know how and why we use information about you. It is also important that you inform us of any changes to your personal information during the recruitment process so that the information which we hold is accurate and current.
2.1 We are Joules Limited, a company registered in England and Wales under company number 2934327 and with our registered office at Joules Building, The Point, Rockingham Road, Market Harborough, Leicestershire LE16 7QU England.
2.2 Joules is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you.
3.1 Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2 If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to firstname.lastname@example.org
4.1 The information that you provide to us is required in order for us to manage the recruitment process. Without this information, we will not be able to consider your application.
4.2 In some instances, we may use information about you to consider you for a role which you haven’t applied for but one for which we think you may be suitable.
5.1 We collect information about you which is relevant to your application. This list is not exhaustive, but includes:
5.1.1 personal details (such as name, date of birth, gender);
5.1.2 contact details (such as your address, personal telephone number and personal email address);
5.1.3 confirmation of your identity/right to work in the UK (such as a copy of your passport);
5.1.4 recruitment information (such as references and other information included in a CV or cover letter or as part of the application process);
5.1.5 information about your previous employment (such as job titles, work history, working hours, training records, professional memberships, salary / compensation history and examples of your work eg portfolios);
Special categories of personal data
5.2 Some of the information which we collect may be special categories of personal data (also called sensitive personal data). Special categories of personal data require a higher level of protection. The special categories of personal data about you which we may collect include:
5.2.1 information about your ethnicity and religious beliefs,
5.2.2 information about your health, including any medical condition or disability that may require an adjustment to allow you to complete a selection process.
6.1 The above information which we collect about you will be obtained through a variety of sources which include:
6.1.1 from you directly as part of the recruitment process;
6.1.2 from third parties as part of the recruitment process (such as employment agencies, background check providers, former employers, from personality profiling tools).
7.1 We use the types of personal data which we have listed above for the following purposes:
7.1.1 The recruitment process (such as 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 UK);
7.1.2 To comply with our legal obligations such as to prevent fraud and equal opportunities monitoring.
8.1 Some of the information which we collect will be special categories of personal data (also called sensitive personal data), such as information about your ethnic background or your health. We will use your particularly sensitive personal information in the following ways:
8.1.1 We will use information about any condition or disability status, to ensure your health and safety in the workplace during the recruitment process and to make reasonable adjustments to allow you to complete the selection process.
8.1.2 We will use information about your race or national or ethnic origin, religion or beliefs, to ensure meaningful equal opportunity monitoring and reporting;
9.1 If you refuse to provide certain information when requested, we may not be able to proceed with the recruitment process, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
10.1 We will comply with data protection law. At the heart of data protection laws are the "data protection principles" which say that the personal information we hold about you must be:
10.1.1 used lawfully, fairly and in a transparent way;
10.1.2 collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
10.1.3 relevant to the purposes we have told you about and limited only to those purposes;
10.1.4 accurate and kept up to date;
10.1.5 kept only as long as necessary for the purposes we have told you about; and
10.1.6 kept securely.
11.1 In accordance with the data protection laws, we need a "lawful basis" for collecting and using information about you. There are a variety of different legal bases for using personal data which are set out in the data protection laws.
11.2 The lawful bases on which we rely in order to use the information which we collect about you for the purposes set out in this statement will be:
11.2.1 using your information in this way is necessary for us to perform the contract between us and you in order to take steps at the request of you prior to entering into the contract; and
11.2.2 using your information is necessary for us to comply with legal and regulatory obligations to which we are subject;
11.2.3 using your information pursuant to our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests);
11.2.4 you have given us your consent to use your information for a particular purpose;
11.2.5 we need to use your personal information to protect your interests (or someone else’s interests) in a life or death situation; or
11.2.6 we need to use your personal information in the public interest.
11.3 ”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. The lawful basis on which we rely in order to use your special categories of personal data which we collect about you will be:
11.3.1 it is necessary in order for us to comply with our legal obligations in our role as an employer;
11.3.2 you have provided your explicit consent to our use of your information;
11.3.3 it is needed in the public interest (such as equal opportunities monitoring); or
11.3.4 less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your vital interests (or someone else’s vital interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.
12.1 We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
12.2 ”Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers:
12.2.1 hosting of the applicant tracking system through which you submit your application
12.2.2 IT services;
How secure is my information with third-party service providers and other entities in our group?
12.3 All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
When might you share my personal information with other entities in the group?
We will share your personal information with other entities in our group as part of the recruitment process where appropriate, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data, recruitment, and provision of maintaining HR files through HR support.
What about other third parties?
12.4 We may share your personal information with other third parties, for example if we outsource any element of the recruitment process. We may also need to share your personal information with a regulator or to otherwise comply with the law.
13.1 We may transfer the personal information we collect about you to the following countries outside the EU in order to perform our contract with you:
13.1.1 USA, China
13.2 There is an adequacy decision by the European Commission in respect of those countries listed above with an asterix (*).This means that those countries are deemed to provide an adequate level of protection for your personal information.
13.3 For the remaining countries which do not have an adequacy decision from the European Commission, we have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection:
13.3.1 The third party organisations based in the US are each subject to the US/EU Privacy Shield. This means that both organisations are part of a scheme which is designed to protect your personal information. As a result, we are not required to obtain specific authorisation to transfer your information to the US.
13.3.2 Standard data protection clauses in the form of template transfer clauses adopted by the European Commission.
13.4 If you require further information about these protective measures, you can request it from the Data Protection Officer.
14.1 We have put in place measures to protect the security of your information. Details of these measures are available upon request.
14.2 Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
14.3 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, contractors and other third parties 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.
15.1 We typically will only use your personal information for the purposes for which we collect it. In limited circumstances we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
15.2 We may use your personal information without your knowledge or consent where such use is required or permitted by law.
16.1 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from our Data Protection Officer. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
16.2 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 a prospective employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy. If you become an employee then your data will be governed by our Employee Privacy Statement.
You are not always entitled to exercise each of these rights. The rights which you are entitled to exercise depend on a number of factors including the lawful basis on which we rely to use your personal data. Therefore, if you make a request to exercise a right which is not available to you, we have the right to decline the request.
Under certain circumstances, by law you have the right to:
17.1.1 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
17.1.2 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
17.1.3 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You 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).
17.1.4 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
17.1.5 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
17.1.6 Request the transfer of your personal information to another party.
17.2 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 your Resourcing team contact
18.1 In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact your Resourcing team contact. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
19.1 You also have the right to complain to the Information Commissioner's Office (the "ICO") if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.