Introduction
This Privacy Notice is intended to provide information regarding the use of personal data about candidates for positions at TopCashback (“TopCashback”, “Company”, “we” or “us”). This Privacy Notice applies to all candidate personal data related to recruitment that is processed by the Company, regardless of whether it is maintained in electronic format or in a structured filing system.
Identity of the Data Controller
TopCashback is the data controller and is responsible for processing your personal data. If you have any questions regarding the content of this privacy notice, you can contact us by email at jobs@topcashback.co.uk or privacy@topcashback.co.uk.
Lawful Basis and Purposes for Processing Personal Data
For recruitment purposes we collect, store, use and otherwise process personal data about job candidates in order to make hiring decisions. The lawful bases for processing include:
a) legitimate interests, including but not limited to the purposes of the recruitment process, assessing and confirming your suitability for employment, facilitating the selection process, conducting reference checks, communicating with you, business process execution and internal management, safeguarding the security of our infrastructure, premises, assets and office equipment, including the prevention of criminal activity, defending legal claims;
b) consent, including obtaining your consent to contact referees, to conduct background checks, to verify information, to consider you for other employment positions with the Company; and
c) legal obligation, including checking your eligibility to work in the UK.
We will notify you of any changes to information we collect or to the purposes for which we collect and process it in this context by updating this Privacy Notice from time to time.
Categories and Sources of Personal Data that We Process
This Privacy Notice covers any of the personal data that candidates submit to the Company for the recruitment process. This may include but is not limited to the following information:
a) Your name, contact details and status;
b) Details of your qualifications, skills, experience and employment history;
c) Information included in your CV or cover letter, such as job history, academic background and attainment, skills and competencies, personal interests, languages spoken, questionnaire results;
d) Job preferences and type of employment sought, willingness to relocate;
e) Names and contact details for references. Please note that it is your responsibility to obtain consent from your references prior to providing us personal information about them;
f) Current and historic salary details together with salary expectations;
g) Details of your current benefit entitlements; and
h) Information about your entitlement to work in the UK.
TopCashback may collect this information in a variety of ways, including directly from candidates, via hard copy and web-based application forms, from recruiters and recruitment agencies, through individual referrals and from test results where relevant to the position. We may also review social medial profiles and consider publicly available information.
We may also collect personal data about candidates from other third parties, subject to your consent or as required by law, including academic history, references supplied by former employers, information from employment background check providers and information from criminal records checks where considered necessary or required by law. The Company will seek information from third parties only once a job offer has been made to you and once we have communicated to you that we will be doing so.
We process limited amounts of special categories of your personal data in order to comply with our legal obligations, when necessary for the purposes of carrying out obligations and to make reasonable adjustments for candidates with disabilities.
Data Sharing: Third Parties
A candidate’s personal data may be shared internally within the group of companies as part of the recruitment process. This includes interviewers involved in the recruitment process, managers in the business area where there is a vacancy, senior management in the case of senior posts, and IT and business systems colleagues if access to the data is necessary for the performance of their roles.
We may need to share some of your personal information with other parties, including in-house and external recruiters and recruitment agencies, hiring managers and third party service providers. When we do so, we ensure that contractual measures are in place where necessary to protect candidates’ personal data.
International Transfers
Personal data may be transferred outside of the UK/EEA, where this happens we will ensure that this is done in a way to protect your data.
We will not use your personal data for any purpose other than the recruitment exercise for which you have applied.
Your Rights
The General Data Protection Regulation provides you with certain rights in relation to the processing of your personal data, including to:
a) Request access to personal data about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you.
b) Request rectification, correction, or updating to any of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
c) Request erasure of personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove personal data where you have exercised your right to object to processing (see below).
d) Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you (e.g. if you want us to establish its accuracy or the reason for processing it).
e) Request the transfer of personal data provided by you (“data portability”), to the extent applicable in the recruitment context. This enables you to ask us to provide you, in machine-readable format, personal data that you have provided to us for transfer to another controller.
f) Object to specific types of processing in some circumstances, including direct marketing, processing based on legitimate interests, processing for research or statistical purposes, and decisions based solely on the basis of automated decision-making, including profiling.
These rights are not absolute and are subject to various conditions under:
i) applicable data protection and privacy legislation; and
ii) the laws and regulations to which we are subject.
Data Retention
Your details will not be kept for longer than is necessary for the recruitment process, unless you are offered employment, in which case all relevant data will be stored as part of your contract of employment.