Underwaterpistol Limited GDPR Candidate privacy notice (UK)

What is the purpose of this document? 

Underwaterpistol Limited is a data controller, which means we are responsible for managing how we keep and use personal information and data about you. It is your responsibility to read and agree to this privacy notice, as you are applying for a role with us (regardless if as an employee, worker or contractor). 

This will highlight to you the reasons why and how your personal data will be used, namely for recruitment process purposes, and how long it will typically be retained for. It provides you with information that we are required to provide under the General Data Protection Regulation (GDPR). 

Data protection principles 

We will comply with data protection laws & principles. This 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. 
  • Kept securely. 

The sort 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 information about you: 

  • The information you have provided to us in your curriculum vitae and covering letter. 
  • The information you have provided on our application form, including name, nationality address, telephone number, personal email address, employment history. 
  • Your named referees, from whom we collect the following categories of data: 1) Name; 2) Job title; 3) Date of employment; 4) Reason for leaving
  • Right to work in the UK, including but not limited to Passport and Visas
  • Any information you provide to us during the hiring process, from the moment of your application submission. 
  • Any other information included as part of the application process, such as tests, tasks and/or portfolios. 

We may also collect, use and store the following "special categories" which include more sensitive personal information: 

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions. 
  • Information about criminal convictions and offences. 
  • Information about your health, including any medical conditions, health & sickness records. 

How is your personal information collected? 

We collect personal information about candidates via the following sources: 

  • You, the candidate. 
  • Our preferred and authorised recruitment agency partners, from which we collect the following categories of data: Name, employment history, qualifications, and any information you have provided to the recruitment agency. 
  • Disclosure and Barring Service in respect of criminal convictions. 
  • Your named referees, from whom we collect the following categories of data: Employment History and sickness records. 
  • Publicly accessible data from third parties such as LinkedIn, Glassdoor, Twitter, Facebook, Instagram 

How we will use information about you 

We will use the personal information 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. 
  • Comply with legal or regulatory requirements. 

It is in our legitimate interest to decide whether to appoint you in the role, seeing as it would be beneficial to our business to appoint someone to that role. 

We will also need to process your personal information to decide whether to enter into a contract of employment or consultancy agreement with you. 

Having received your CV and covering letter and/or your application form, 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 do decide to contact you for an interview, we will use the information you provide to us at the interview/s to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and may carry out a criminal record check where applicable before confirming your appointment. 

If you fail to provide personal information 

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further. 

How we use particularly sensitive personal information 

We will use your particularly sensitive personal information in the following ways: 

  • We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview. 
  • We will use information about your race or national or ethnic origin, religious beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. 

Information about criminal convictions 

We envisage that we will process information about criminal convictions. 

We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular: 

  • We may, from time to time be required by our clients to carry out criminal record checks for those carrying out roles exposed to sensitive data 

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. 

Automated decision-making 

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. 

Data sharing 

Why might you share my personal information with third parties? 

We will only share your personal information with the following third parties for the purposes of processing your application: third-party service providers

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. 

Data security 

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. Details of these measures may be obtained from our Data Protection Officer 

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. 

Data retention 

How long will you use my information for? 

We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to appoint you to a role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy. Rights of access, correction, erasure, and restriction 

Your rights in connection with personal information 

Under certain circumstances, by law you have the right to: 

  • 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. 
  • 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. 
  • 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). 
  • 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. You also have the right to object where we are processing your personal information for direct marketing purposes. 
  • 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. 
  • Request the transfer of your personal information to another party. 

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 The Recruitment Team in writing. 

Right to withdraw consent 

When you applied for this role, you provided consent on your application date to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact The Recruitment Team. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely. 

Data protection officer 

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO (info@underwaterpistol.com). You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. 

By applying for a role with Underwaterpistol Limited, you acknowledge that from the date of application, you have read and understood this Candidate Privacy Notice.