Candidate Privacy Notice
Brightwell[1] are registered at One America Square, 17 Crosswall, London, England, EC3N 2LB (“we”, “us” or “our”) and are data controllers for any relevant Data Protection Regulations, including EU GDPR, UK GDPR and DPA 2018). We are committed to protecting and respecting your privacy.
This Privacy Notice sets out the basis on which we will process any personal data we collect from you, or that you or third parties provide to us, in connection with your membership in the Scheme and which relates to you or to any individual connected with you.
Please read this Privacy Notice (“Notice”) carefully so that you understand your rights in relation to your personal data, and how we will collect, use, and process your personal data.
In a situation where you provide us with your personal data to share with a third party who will provide a service to you directly, they are the data controller of that personal data and you are strongly advised to review their own privacy notice for details as to how they handle your personal data.
This Notice explains our policy in relation to:
- what information we collect about you,
- how we use your information,
- who we share your information with,
- where and how long we will keep your data,
- how we keep your information safe,
- your rights regarding the personal information you provide to us,
- technical information that we collect about you (including via the use of cookies on our website), and
- who you can contact if you have questions or complaints about how we process your personal data.
The types of data we receive
We will receive the following information about you either directly from you or from third parties in connection with your application, such as recruiters, referees, and organisations that provide background checks:
- identity information such as title, full name, gender, citizenship, date of birth and proof of eligibility to work
- contact details such as home and work address, phone numbers, email addresses, emergency contacts and next of kin information
- data with respect to education, professional training and previous career performance including qualifications, references or curriculum vitae information
- identity and contact information and references from previous employers or professional contacts
- personal and family details
- data with respect to career commencement and development including date of hire, employee category, and full time or part-time status and
- Information relating to publicly available social media content relating to your name.
How we process your information
We process your information as follows:
- To identify and evaluate you for employment positions. This is necessary for our legitimate interests to properly evaluate and contact employment candidates.
- To determine and validate your qualifications for employment. This is necessary for our legitimate interests to properly evaluate employment candidates.
- To conduct right to work in the UK
- To conduct background checks to the extent permitted under applicable law (including checking references, qualifications, criminal records checks, credit checks and publicly available social media activity). This is necessary for our legitimate interests to properly screen employment candidates.
- If you are a successful candidate, to create an employment record. This is necessary for our legitimate interests to create employment records.
- To the extent permitted or required by applicable law, to conduct employment monitoring. We do this with your explicit consent. It is also necessary for our legitimate interests to conduct employment.
- To communicate with you. This is necessary for our legitimate interests to communicate employment decisions to candidates.
Where we store your information
The information that we collect from you will only be processed within European Economic Area
(“EEA”).
How we share your information
We share your information with selected recipients. These categories of recipients include:
- Organisations who provide background checking services to verify the information that you provided as part of your application; and
- referees, as selected by you, to identify you to them so they can provide a reference.
- Recruitment Partners. We partner with Sanderson who support us with all aspects of the recruitment journey up to offer acceptance. They will not have visibility of any background checks performed as part of your onboarding. Their privacy policy can be found here; Group Privacy Notice_website_v1.7 [March 2024]
The security of your personal data
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through electronic means to us; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and Organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification.
Data retention
We will retain your information as follows:
Successful Candidates: 6 years after employment ceases
Unsuccessful Candidates: At least 3 months but no longer than 12 months (unless applicants are notified, or records are required to defend an action)
Right to work and Background check report: At least 3 months but no longer than 12 months after employment ceases.
Your information will be retained for longer if required by law or a court order and/or as needed to defend or pursue legal claims.
Your rights
You have certain rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights.
Please note that we will require you to verify your identity before responding to any requests to exercise your rights by completing the attached Data Subject Access Request form. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please fill out the attached form and submit it insert DPQueries@BrightwellPensions.co.uk
- Access. You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
- Correction. You have the right to require us to correct any personal data held about you that is inaccurate and have incomplete data completed (including by the provision of a supplementary statement). Where you request correction, please explain in detail why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that whilst we assess whether the personal data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
- Erasure. You may request that we erase the personal data we hold about you [in the following circumstances]:
- you believe that it is no longer necessary for us to hold the personal data we hold about you, for instance if you decide that you no longer wish to submit an application
- we are processing the personal data we hold about you based on our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such personal data; or
- you believe the personal data we hold about you is being unlawfully processed by us.
Also note that you may exercise your right to restrict our processing of your personal data whilst we consider your request as described below. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. We will retain the personal data if there are valid grounds under law for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case.
- Restriction of Processing to Storage Only. You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances.
Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defense of legal claims or for another’s protection). You may request that we stop processing and just store the personal data we hold about you where:
- you believe the personal data is not accurate for the period it takes for us to verify whether the data is accurate
- we wish to erase the personal data as the processing we are doing is unlawful but you want us to simply restrict the use of that data
- we no longer need the personal data for the purposes of the processing but you require us to retain the data for the establishment, exercise or defence of legal claims; or
- you have objected to us processing personal data we hold about you based on our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at DPQueries@BrightwellPensions.com
and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a complaint with a supervisory authority.
Changes
We may update this notice from time to time and we will supply updated to copies to those organisations that supply recruitment services to Brightwell.
Contact
If you have any questions or concerns about this notice, please contact us at:
E-mail: DPQueries@BrightwellPensions.com
or
Data Governance Officer
BT Pension Scheme Management Limited One America Square
17 Crosswall
London EC3N 2LB
If you believe that we have handled your data incorrectly you can contact the Information Commissioner’s Office directly.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
www.ico.org.uk
[1]
BTPS Group including BT Pension Scheme Management Limited and BT Pension Administration Limited trading as Brightwell. Registered in England and Wales (No. 05154287) Authorised and regulated by the Financial Conduct Authority (Firm Reference Number: 486368).
