Recruitment Privacy Policy

Last updated: December 2022

What is the purpose of this document?

Headland is a “data controller”. This means that we are responsible for deciding how we hold and use any information which can be used to identify you (“Personal Data”). It makes you aware of how and why your Personal Data will be used, namely for the purposes of the recruitment exercise to assess your suitability for a role at Headland.

It provides you with certain information that must be provided under the Data Protection Act 2018 which incorporates the UK General Data Protection Regulation (GDPR) and any legislation implemented in connection with the GDPR. 

Data protection principles

We will comply with Data Protection Legislation and principles, which means that your data will be:

  • Used lawfully, fairly and in a transparent way;
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date;
  • Kept only as long as necessary for the purposes we have told you about; and
  • Kept securely.

The kind of information we hold about you

In connection with your application for work with us, we will collect, store, and use the following categories of Personal Data about you:

  • The information you have provided to us in your curriculum vitae, application form and any covering letter accompanying your application;
  • Information confirming your eligibility to work in the UK; and
  • Any information you provide to us during an interview relevant to assessing your suitability for the role;

The lawful basis we rely on for processing personal data as part of your application is processing necessary to perform a contract or to take steps at your request, before entering a contract.

The lawful basis we rely on for confirming your eligibility to work in the UK is to comply with our legal obligation.

Sensitive personal data

We may also collect, store and use the following types of more sensitive Personal Data:

  • Information about your race or ethnicity and sexual orientation for the purposes of equal opportunities monitoring. Providing us with this information is not mandatory. If you don’t provide it, it won’t affect your application; or
  • Information about your health, including any medical condition for the purposes of making reasonable adjustments within the proposed role and/or during the interview or assessment day. If you provide us with any information about reasonable adjustments you require under the Equality Act 2010 the lawful basis we rely on for processing this information is to comply with our legal obligations under the Act and relates to our obligations in employment.

How we will use personal data about you

We will use the Personal Data we collect about you to:

  • assess your skills, qualifications, and suitability for the role.
  • carry out background and reference checks, where applicable.
  • communicate with you about the recruitment process.
  • keep records related to our hiring processes and to help us keep track of applications that were made directly by you and those that were made via a recruitment agency.
  • comply with legal or regulatory requirements.
  • decide whether to hire you.
  • add you to our talent pool to inform you about future vacancies.
  • defend or institute a legal claim.

How we use your sensitive personal data

We will use your sensitive Personal Data in the following ways:

  • to provide appropriate adjustments during the recruitment process, for example adjustments related to access requirements
  • to ensure meaningful equal opportunity monitoring and reporting. The data used in any reports will be anonymised.

Only the People Team have access to this information.

Having received your CV we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and carry out a criminal record check and other necessary checks, where required before your start date.

We are required to perform all of these processing actions in order to engage in the employment contract with you.

How is your personal data collected?

We collect Personal Data about applicants from the following sources:

  • You, the applicant.
  • Recruitment agencies, from which we collect the following categories of data: contact information, qualification history, employment history, education details.
  • Disclosure and Barring Service in respect of criminal convictions.
  • Your named referees, from whom we collect the following categories of data: Employment history, role, duration and reference data.

Automated decision-making

We do not use automated decision making at any stage during our recruitment process.

Data sharing

We use Hibob (our HR system), who act as processors and are third parties who provide elements of services for us. Data will only be entered into hibob if you are successful during the recruitment process and are offered a role with Headland. Hibob cannot do anything with your Personal Data unless we have instructed them to do it.

Any third-party service providers are required to take appropriate security measures to protect your Personal Data 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.

All of your Personal Data will be held within data centres the U.K.

Data security

We have put in place appropriate security measures to protect your Personal Data and we limit access to your Personal Data to those employees, and other third parties who have a business need-to-know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

Data retention

We only keep your personal data for as long as reasonably necessary. If you are unsuccessful, your personal details will be removed after 12 months.  

Your rights

Your rights in connection with Personal Data
Under certain circumstances, by law you have the right to:

  • Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data 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 Data where you have exercised your right to object to processing (see below).
  • Object to processing of your Personal Data 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. You also have the right to object if we process your Personal Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your Personal Data to another party.

If you want to review, verify, correct or request erasure of your Personal Data, please contact marking it to the attention of the People Team.