Effective Date: 14 September 2020
Last Reviewed: August 2020
What is the purpose of this document?
MDE Services Group Limited and its affiliated companies including MDE Healthcare Services in the United Kingdom and MDE Healthcare Services Inc. in the United States (MD Group) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. This privacy notice is made available to you because you are applying to work with us (whether as an employee, worker, director or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation (GDPR).
Data protection principles
We will comply with data protection law 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.
- 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 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, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications.
Under certain circumstances, we may collect additional categories of personal information, in relation to any necessary background checks that we may need to conduct relevant to the role you are applying for.
Any information you provide to us during an interview
Any other information provided as part of the selection process including tests, written exercises, and presentations.
We may also collect, store and use the following “special categories” of more sensitive personal information:
Information about your health, including any medical condition, health and sickness records.
Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about candidates from the following sources:
You, the candidate.
From any of our employees, contractors, directors who would have referred you to us.
From any recruitment agency who has referred you or your details to us, which may include your name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications.
Disclosure and Barring Service in respect of criminal convictions.
Your named referees, from whom we may collect your previous job role, your dates of employment, your reason for leaving and details relating to your performance and/or capabilities.
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 interests to decide whether to appoint you to the role for which you have applied since it would be beneficial to our business to appoint someone to that vacancy.
We also need to process your personal information to decide whether to enter into a contract of employment 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 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 if necessary carry out a criminal record check) 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 a credit check or 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 to any interview.
Information about criminal convictions
We do not envisage that we will regularly hold information about criminal convictions.
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences solely as part of any safeguarding and/or legally required verifications. We are allowed to use your personal information in this way to carry out our legal obligations. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We do not envisage sharing your personal information with any third parties for the purposes of processing your application, apart from obtaining references and conduct background checks as applicable. Your personal information will also be stored in our systems which are hosted by third party providers.
All our third-party service providers 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.
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.
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.
How long will you use my information for?
We will retain your personal information in accordance to our internal data retention policy. Our retention criteria is based upon the need for us, in the event of a legal claim, to show 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.
If you have interviewed you, we will retain certain personal information in accordance to our internal data retention policy, along with the role you applied for and the agency you came through where applicable. The reason being is that when working with agencies we need to protect our legitimate interests and prove that you were not under a candidate ownership position with an agency should we discuss any opportunity with you.
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.
Right to withdraw your consent for our use of your personal information, where applicable.
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 person named below in writing.
Data protection officer
We have appointed Sarah OUIS, Legal Counsel & Data Protection Officer 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 them. 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.
If you have any questions about this privacy notice, please contact HR@mdgroup.com or our Data Protection Officer at firstname.lastname@example.org