INSIGHTS LEARNING & DEVELOPMENT LIMITED (“Insights”)
RECRUITMENT PRIVACY NOTICE (“Privacy Notice”)
Thank you for your interest in applying for a position at Insights! Before you provide us with your CV, application form or personal information, we want to tell you about what we will do with the personal information you give us throughout the application and recruitment process.
This Privacy Notice explains what personal information we will collect and hold about you and how we will use that information about you during the application and recruitment process. We may collect personal information about you which doesn’t relate to the application and recruitment process from time to time. When we do, this Privacy Notice may not apply. Please ensure that you read and understand all privacy notices which we provide to you.
We ask you not to provide us with your personal information (or allow anyone else to pass your personal data on to us on your behalf) until you have read this Privacy Notice and are happy that you understand it. If you are providing a CV, application form or other information about, or on behalf of, another person, you must make sure that you tell them what you are providing to us and have their consent to do so. You must also make them aware of this Privacy Notice before passing any personal information on to us. If you have already provided us with personal information and you no longer wish for us to process your personal information, please contact our Data Protection Officer or your Insights contact, and we’ll do what we can to assist you.
We want you to be well-informed about how we and why we collect your personal information and how it is used throughout the recruitment process. So, please feel free to ask us questions, raise concerns or exercise your rights (these are detailed further down) at any time. Our Data Protection Officer can be contacted directly at: dpo@insights.com
We try to continuously improve our recruitment process, so we may update this Privacy Notice from time to time. It is important that you check the website for updates to the Privacy Notice from time to time.
Given that this is our recruitment privacy policy, we know you’re likely to know a little about us, however, just in case, we are Insights Learning & Development Limited, a company registered in Scotland (company number SC107074) with our registered office and Global Head Office located at Terra Nova, 3 Explorer Road, Dundee, DD2 1EG. We are a controller of the personal information provided to us during the application and recruitment process, which means that we determine how and why personal information is processed.
In this Privacy Notice when we say “Insights”, “we”, “us” or “our”, we are referring to “Insights Learning & Development Limited”.
At Insights, we love to identify the best talent and encourage people to apply for jobs with us. To enable us to run a smooth and impartial recruitment process, we need to process personal information about all potential candidates. We limit the collection and processing of information necessary to achieve one or more purpose as identified in this notice. The personal information which you collect about you may include:
Special Category Personal Information
Some of the information which we ask you to provide may be ‘special category information’. Special category information simply means personal information which relates to your racial or ethnic origin, religious or philosophical beliefs, trade union membership, physical or mental health condition and/or sexual orientation. We ask you not to provide any special category information to us unless we specifically ask you to. Please be aware that we may not be able to process special category information even when it has been provided inadvertently. We may simply delete all documents containing special category information where we have no lawful basis to hold it.
Usually, we collect personal information directly from you in circumstances where you wish to apply for a position with us, whether this is online, through emails to us, at a recruitment fair, or otherwise. However, there are occasions where we may learn about you through third parties such as recruitment agencies, where an employee recommends you, or from other sources such as LinkedIn. If you are successful, we may also collect information about you from previous employers and/or academic institutions which you have attended. This Privacy Notice applies in respect of all recruitment activity whether you have provided personal information directly to us or it has been provided to us through a third party.
We collect your personal information for the following specified purposes:
A controller may only process personal information where there is a lawful basis allowing them to do so. When we process personal information during the recruitment process, generally, we will rely on the following lawful basis’:
We want to ensure that the personal information which we collect, and the processing of it, is proportionate. We will notify you of any changes to the personal information we collect, or the purposes for which we collect and process it by updating this Privacy Notice. It is important that you check the website for updates to this Privacy Notice from time to time.
We will share personal information with Insights employees who have responsibility for recruitment, such as members of the Insights Resourcing Team, the wider People Team, and other parties directly involved in the recruitment process, for example the Hiring Manager. Other members of staff may have access to personal information where such access is required for the due performance of their function. For example, members of the IT department may have sight of your personal information while resolving an issue for an Insights employee. Employees who access personal information are aware of their obligations to only process personal information in accordance with the UK Data Protection Act 2018 and, where applicable, the GDPR.
Where you have applied through a recruitment agency, we may share personal information with them. Please ensure that you read the privacy notice of any recruitment agencies before permitting them to pass your personal information to us.
Where you are successful, we may share personal information with third parties to obtain references and to perform pre-employment checks. If you are employed with us, you will be required to sign an employment contract which may contain additional details about how your personal information will be handled and stored once, you are an employee.
Please note that pre-employment screening and references are only conducted once a conditional offer of employment has been made. As such, these checks are not carried out on most applicants.
Depending on the role applied for, we may conduct criminal record, credit, and directorship checks. We will only carry out such pre-employment checks where we have a legal requirement to do so, where such checks are generally accepted principles of good practice and where such checks are directly relevant to the particular position applied for. We will advise you when we need to carry out these checks and will seek your consent where appropriate to do so. We may share your contact details with our pre-employment screening provider, who will contact you to arrange for the relevant checks to be conducted in accordance with our written instructions. We may be required to collect and process additional personal information about you as part of our pre-employment checks; if we do, we’ll let you know. We won’t pass your personal information to our third-party provider, for the purpose of pre-employment checks, without letting you know what personal information will be passed on and how it will be processed. Where necessary, we will ask for your consent.
We use an Applicant Tracking System to manage our online job postings and applications. CATS One (www.catsone.com) processes and hosts your CV and/or application forms (which contain personal information about you) on behalf of Insights, as a processor. When CATS acts as a processor, it will collect and process your personal information in the manner and for the purpose determined by Insights.
Please be aware that when you access the CATS One website, CATS may collect personal information directly from you (including though the use of cookies) for its own purposes. Where CATS does collect personal information directly from you, it does so as a controller. CATS sets out how and why it collects and processes personal information about you on its website (via its Privacy Policy and Cookies Policy). Such processing is separate from the processing activities which CATS carries out for us. When CATS acts as a controller, it is responsible for its own compliance with data protection laws.
Personal Information may be held at our offices and those of our group companies. It may also be held at the offices of third-party agencies, cloud providers, service providers, representatives and agents. Where personal information is stored or transferred outside of the EEA or the UK, we will ensure that appropriate measures are in place to ensure its adequate protection. A full list of Insights group companies can be found on our website. For intra-group transfers, Insights use the EC Model Clauses (where required), to ensure the safety of your personal information. Further details can be viewed in our General Privacy policy: https://www.insights.com/privacy-policy/
Our processors may be located outside of the UK and/or the EU, so your personal information may be transferred and stored outside of the UK and/or the European Economic Area. Where Insights transfers or stores your personal information outside the UK and/or the EU, we will put appropriate measures in place to ensure that any personal information transferred is subject to adequate legal protections through a mechanism approved by the European Commission and/or the UK Government, as applicable.
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your personal information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with data security breaches. We will notify you and any applicable regulator of a data security breach, where we are legally required to do so.
We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful, the nature of the information concerned and the purposes for which it is processed.
If your application is not successful, we will keep your personal information for 12 months from the date on which we were last in contact with you. This is to ensure that, where possible, we can re-engage with you should alternative suitable roles arise and to assist us to resolve any issues or queries about the recruitment process which may arise. Unless you are successful, all personal information which is held about you will be deleted or destroyed, at the end of the 12 months and no record of your application will be held by us after then. For the avoidance of doubt, this includes any digital records held in our Applicant Tracking System, as well as all locally held personal information, in either soft or hardcopy form. We may delete your personal data before the 12 months’ has ended if you have exercised your right to object to the processing and we have no other lawful basis to continue the processing.
If your application is successful, your personal information will be transferred to our HR administration department and processing will be subject to your employment contract and employment privacy notice.
The law on data protection gives you certain rights in relation to the personal information which we hold about you. These are:
We may need to request specific information from you to help us confirm your identity or verify your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you have any questions about this Privacy Notice for Recruitment or data protection or privacy matters generally, please contact our Data Protection Officer.
If you would like exercise any of your rights as set out in part 10 of this Privacy Notice, please contact the Resourcing team (recruitment@insights.com) or Insights’ Data Protection Officer: Alternatively, please speak to your contact within the People Team.
The contact details for the Data Protection Officer are:
The Data Protection Officer
Insights Learning and Development Limited
Terra Nova
3 Explorer Road
Dundee
DD2 1EG
Scotland
UK
Tel: +44 (0)1382 908050
E-mail: dpo@insights.com
Whilst we hope that you will not need to, if you do wish to complain about how we handle personal information, you may contact our Data Protection Officer as above. Where you are unsatisfied with the response of the Data Protection Officer or are unable to get your issue resolved, please be aware that you also have the right to complain to the relevant data protection Supervisory Authority. The UK Information Commissioner’s Office (ICO) is the relevant Supervisory Authority for Insights and its European branch offices. We would appreciate the chance to deal with your concerns before you approach the ICO. You can however contact the ICO as follows:
Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Email: casework@ico.org.uk
Telephone: + 44 303 123 1113
Website: www.ico.org.uk
Status of Privacy Notice and changes
This Privacy Notice is effective from 25th May 2018. We may change it from time to time so please check regularly to keep informed of updates.
Last updated: 07/10/20 (version 3.1)