BGRS EU Careers Privacy Notice
Last Modified: June 2018
As a talent mobility/relocation management business (BGRS), we are entrusted everyday with collecting and managing person-identifiable information of applicants, and employees. In doing so, we observe the appropriate EU/UK data protection laws, and are committed to protecting and respecting people’s privacy and rights. Specifically, we act as a “Data Controller” in respect of the information gathered and processed by this website.
In order that you are reliably informed about how we operate, we have developed this EU Careers Privacy Notice, which describes the ways in which we collect, manage, process, store and share information about you as a result of you visiting this site and engaging with BGRS. The EU Careers Privacy Notice also provides you with information about how you can have control over the use of your data.
If you have any comments/queries regarding our use of your data, please contact our Global Data Protection Officer at firstname.lastname@example.org
Alternatively, you can write to our Global Data Protection Officer at BGRS, 6th Floor, 20 Canada Square, London, UK E14 5NN
2. What information do we collect about you?
If you apply to work for us, we will collect a range of information from you, including your name, home address, date of birth, e-mail address, telephone number as well as your employment history and documentation to support your right to work. This is referred to as your “personal data”.
We will also collect some sensitive information from you (known as “special categories of data”), which includes your racial or ethnic origin, religious beliefs, sexual orientation and any disabilities which you may have. Please be advised that we will treat all special categories of data with extra security, ensuring specifically that only authorised individuals are able to access it. This is additional to the technical controls that we routinely apply to all data, as described in section 6 below.
We will collect your data from you directly, and therefore as part of this website, we will ask you to complete a number of questions. We may also collect information from you when corresponding with you by telephone, email or letter.
Please note that should you be successful in your application, all of this data may form part of your employment record.
Please also be advised that when you visit this website, and even if you do not make a job application, cookies will be used to collect information about you such as your Internet Protocol (IP) address, which connects your computer or mobile device to the Internet, and information about your visit, such as the pages you viewed or searched, page response times, downloaded errors etc. We do this so that we can measure our website’s performance and make improvements in the future. Cookies are also used to enhance this website’s functionality and personalization, which includes sharing data with third party organizations. You can control this by adjusting your cookies settings as described in our Cookies Policy.
3. How will we use the information?
We use the data collected from you for the specific purposes listed in the table below. Please note that this table also explains:
- the legal basis for processing your data, linked to each processing purpose; and
- in what circumstances your data will be shared with a third party organization.
|Purpose for processing data||Legal basis for processing data||Third party organisation with whom data is shared|
|To receive, and undertake initial review of, job applications made using this website.||To fulfil contractual obligations this includes taking action before entering into a contract.||None.|
|To liaise with applicants by email or phone: this includes updating applicants on the progress of their application, organizing a telephone or face-to-face interview.||To fulfil contractual obligations this includes taking action before entering into a contract.||None.|
|To check applicants’ legal right to work.||To fulfil a legal obligation under Immigration, Asylum and Nationality Laws, and Immigration Restrictions on Employment Orders.||Government Departments i.e. Home Office (UK).|
|To understand any criminal convictions held against applicants and/or check criminal records where appropriate.||To fulfil contractual obligations this includes taking action before entering into a contract.||Disclosure and Barring Service (DBS), Sterling Backcheck.|
|To make reasonable adjustments for individuals at interview where appropriate.||Both informed and explicit consent, given that this information will include special categories of data. Legal obligation under the Offer of Employment (Section 1), Employment Rights Law.||None.|
|To contact successful applicants’ chosen referees.||To fulfil contractual obligations this includes taking action before entering into a contract.||Basic details will be shared with applicants’ chosen referees for identification purposes.|
|For successful candidates to create a personnel file.||To fulfil contractual obligations this includes taking action before entering into a contract.||HR system and Payroll system.|
|To report upon the diversity of candidates where required by law.||To comply with a legal obligation, and explicit consent, given that this information will include special categories of data.||Government Departments i.e. Equalities Commission.|
4. Your rights?
Right to access to personal information
You have the right to obtain written confirmation from us whether your personal information is being processed by us or by a third party.
You have the right to access any personal information we hold about you.
You can make a request to access your information by contacting us at:
Global Data Protection Officer
20 Canada Square
London E14 5NN
Or by email at email@example.com
Upon receipt of your subject access request, we will ask you to provide sufficient information to prove your identity and address before any personal information is released to you.
If you make a subject access request through a third party, such as a solicitor, it will be the responsibility of the third party to provide evidence to demonstrate that they are entitled to act on your behalf. This can take a form of a power of attorney or an appropriate written authority.
Although there is no fee for meeting your request we reserve the right to charge a reasonable fee if, in our reasonable judgement the request is manifestly unfounded, excessive or repetitive.
Any fee charged will be based upon the administrative cost of providing the information.
We have one month from the date of receipt of your request to comply.
If you request large amounts of information, we may ask you to specify in more detail the information you require.
Right to rectification
You have the right to request that we rectify personal information which is inaccurate or incomplete. In the first instance contact the HR Team in writing, specifying the inaccurate or incomplete personal information. Provide them with the correct personal information and ask them to rectify it.
We are required to rectify the information within one month. This can be extended to two months if the request for rectification is complex.
If you feel that your request for rectification is not being dealt with, you can escalate your request to the Global Data Protection Officer at the address given above.
Right to erasure (to be forgotten)
You have the right to request the deletion or removal of personal information where there is no compelling reason for its continued processing. Individuals have a right to have personal information erased and to prevent further processing in the following circumstances:
- Where the personal information is no longer necessary in relation to the purpose for which is was originally collected of processed;
- When you withdraw your consent for your personal information to be processed;
- When the individual objects to the processing and there is no legitimate interest for the personal information to be processed;
- Personal information has unlawfully been processed;
- Personal information must be erased on the order of the courts.
We may refuse to comply with your request for erasure if we are required to comply with a legal or statutory obligation or if the personal information will be required for the purpose of resolving a claim, complaint or in the defence of a claim or complaint.
Right to restrict processing
You have the right to restrict the processing of your personal information in the following circumstances:
- Where you contest the accuracy of the personal information which is being processed. You can ask for the restriction to be put in place until you are satisfied that the inaccuracies have been rectified;
- The processing of the information is deemed to be unlawful but you do not want your personal information to be erased;
- The personal information is no longer required by us but you would like us to retain it to establish, exercise or defend a legal claim.
Right to object
You have the right to object to:
- the continued use of your data for any purpose listed in section 3 above for which consent is identified as the lawful basis for processing i.e. you have the right to withdraw your consent at any time.
- the continued use of your data for any purpose listed in section 3 above for which the lawful basis of processing is that it has been deemed legitimate.
5. Is the processing of information likely to cause individuals to object or complain?
BGRS is not aware of any justifiable reasons that would constitute a legitimate reason for objecting or complaining about the way we process or control information.
6. How long will we retain information for?
If your application for employment is unsuccessful, BGRS will hold your account data on file for six (6) months after the end of the recruitment process.
If you agree, BGRS will hold your account data on file for a further six (6) months for you to consider other employment opportunities within BGRS. At the end of that period, or once you have withdrawn your consent, your data is deleted and account closed.
If your application for employment is successful, BGRS will typically retain information for a period of six (6) years. This is due to regulatory reasons and to ensure our business records are adequate.
7. Overseas transfers
Information that we collect about you is shared within the BGRS family globally as appropriate, and with approved third party suppliers and business partners. Our data sharing and access is conducted under agreed contract in line with EU standard contractual clauses.
8. Data privacy and security
At BGRS, we maintain a comprehensive data privacy and security work program, which includes processes for ensuring that data protection is a key consideration of all new and existing IT systems that hold personal data. Where any concerns, risks or issues are identified, we conduct relevant impact assessments in order to determine any actions that are necessary to ensure optimum privacy.
We also maintain an active information security work program which seeks to protect the availability, confidentiality and integrity of all physical and information assets. Specifically, this helps us to:
- Protect against potential breaches of confidentiality;
- Ensure all IT facilities are protected against damage, loss or misuse;
- Increase awareness and understanding of the requirements of information security, and the responsibility of our colleagues to protect the confidentiality and integrity of the information that we handle, and
- Ensure the optimum security of this website.
9. Location tracking via our website
Geo-location tracking, which shows us where you are in the UK or EU, is not used on this website.
10. Changes to our Privacy Notice
Questions and comments regarding this Privacy Notice are welcomed, and should be sent to our Global Data Protection Officer at firstname.lastname@example.org
Alternatively, you can write to our Global Data Protection Officer at BGRS, 6th Floor, 20 Canada Square, London, UK E14 5NN
You can also contact our Global Data Protection Officer if you have any concerns or complaints about the way in which your personal data has been handled as a result of you using our website.
Alternatively, you have the right to lodge a complaint with our Main Establishment Supervisory Authority in the UK, namely The Information Commissioner, who may be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire UK SK9 5AF or https://ICO.org.uk