Recruitment privacy notice

1 Council Contact Details

1.1 West Northamptonshire Council
Registered Office:
One Angel Square
Angel Street
Northampton
NN1 1ED

1.2 We recognise that privacy is important. We have developed this Privacy Notice to inform you of how we will use the information you submit through this recruitment webpage, or in any other way as part of a job application or job search process.

2 Information that we hold

2.1 This Privacy Notice applies to all personal data provided by you in your job application, any subsequent information supplied by you in connection with your application and any information obtained from third parties such as prior employers, the Disclosure and Barring Services Bureau and other sources.

This includes:

name, address, email address, telephone number, or other contact information
CV, cover letter, previous work experience, education, transcripts, or other information you provide for our consideration
information provided by you regarding your application
names and contact information for referees
photographs used during a recruitment exercise and for building access passes
reference number for any required professional registration
whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process
proof of your entitlement to work in the UK and
equality monitoring information, including information about your gender, ethnic origin, sexual orientation, age, health and religion or belief
employment references and the results of any pre-employment screening
the outcome and results of any interviews or tests which formed part of the recruitment process
pay details, national insurance number, tax coding and details of the bank or building society account and Information about your current level of remuneration, including benefit entitlements

It is your responsibility to obtain consent from referees before providing their personal information to us.

Confidential References - Please be aware that the Council applies the exemption under Schedule 2 of the DPA 2018. This means that confidential references provided to the Council by other and previous employers will not be disclosed in any circumstances. Where an employee makes a Subject Access Request (SAR) any confidential references in their records or on file, will therefore not be shared with them.

Data will be stored in a range of different places, including on your application record, in electronic HR Management Systems and on other IT systems (including email).

3 How the information is obtained

3.1 Most of the personal information we process is provided to us directly by you for one of the following reasons:

for the purposes of the recruitment process from receipt of your application and throughout the recruitment process
to make an appointment and undertake any required pre-employment checks
equality Reporting (this data is anonymised) and
to respond to Freedom of Information (FOI) requests

We also receive personal information indirectly, from the following sources in the following scenarios:

Referees
Disclosing and Barring Service (where required)
Occupational Health (where required)
Professional Bodies eg CQC; HCPC registration etc

3.2 There are a number of reasons why we need to collect and use your personal information. Generally, we collect and use personal information where:

it is necessary to meet our legal obligations (state relevant legislation)
you have requested a service from us
you have entered into a contract with us
it is necessary to protect public health
it is required for the defense of legal cases
it is needed for employment purposes
you, or your legal representative, have given us your consent
you have made your information publicly available
it is necessary for law enforcement reasons and to prevent, and detect fraud or crime
we need to protect individuals from harm (in an emergency); or
it is necessary for archiving, research, or statistical purposes - For these purposes your data would be used in a pseudonymised format (name and other identifying information replaced with a unique number)

Where we process special category data such as health data to facilitate reasonable adjustments we rely on Article 9 2(b) carrying out our obligations and exercising specific rights in the field of employment.

The council also processes information from other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief in line with the Equality Act 2010. In addition we rely upon Article 9 2 (g) for the purpose of equality of opportunity monitoring.

For some roles, the council is obliged to seek information about criminal convictions and offences. Where the council seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

4 What we do with the information

4.1 The application information you submit is used for the following purposes:

to assess your skills, qualifications and interests against our career opportunities
to verify your information and conduct reference checks
to conduct security and background checks if you are offered a job
to communicate with you and inform you of career opportunities
to create and submit reports as required by law or regulation
to improve our recruitment process; and
legal defence as necessary

If you accept employment with the Council, the information collected will become part of your employment record and will be used for employment purposes. Anonymised personal data will also be used by the Council for the purposes of monitoring equality of opportunity.

4.2 We may share this information with a range of different types of people and organisations depending on the nature of the employment relationship or the statutory requirements that we have to comply with. This may include:

OPUS Northamptonshire
LGSS Law
Local Government Organisations (particularly LGSS and other relevant partner County, City and District Councils) – specify Lead Authority Model CCC, MKC and Northamptonshire Children’s Trust
DBS Processing – Kent County Council
North Northamptonshire – host and lead
Current, Past and Prospective employers
Councillors and Political Parties
Central Government Departments
HML (Occupational Health)
Regulatory Bodies, Investigators and Ombudsman (for example Ofsted, CQC, Local Government Ombudsman, HSE)
Courts and Tribunals
Legal Representatives
Fraud Prevention Agencies
Law Enforcement Agencies, such as the Police

We participate in the Cabinet Office's National Fraud Initiative, a data matching exercise to assist in the prevention and detection of fraud. We are required to provide particular sets of data to the Minister for the Cabinet Office for matching for each exercise.

4.3 We do not apply automated decision making and our recruitment processes are not based on automated decision-making.

Automated decision-making is where decisions are made about you without any human influence on the outcome. These may affect your legal rights or have an impact on your circumstances, behaviour or choices.

4.4 We do not apply profiling and our recruitment processes do not use profiling.

Profiling is where you analyse parts of an individual’s personality, behaviour, interests and habits to identify their preferences, make predictions or decisions about them.

5 How long we keep your information for and how we securely dispose of it after use

5.1 We keep your personal information for all aspects of processing in line with the council’s retention schedules. In addition, data is also retained in line with the specific HR Records Retention Schedule.

We only keep information for as long as it is needed.

If your application for employment is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process. (In exceptional circumstances, we may need to retain your record for a further duration in order to comply with UKVI/Home Office requirements).

If you register and agree to allow us to keep your personal data on file, we will hold your data on file for 6 months from the date of your last access/update.

At the end of that period, your data will be deleted or destroyed.

Successful applicant data will become part of an employment record and will be used for employment purposes and any personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment with us. The periods for which your data will be held will be provided to you in the employee privacy notice and retention schedule.

5.2 We will securely dispose of your information in line with the council's retention schedules.

6 How we store your information

6.1 Your information is securely stored on the council’s systems.

Only relevant employees of the Human Resource (West Northamptonshire Council) and relevant recruiting managers will have access to your data for the purposes listed above. Where third parties are involved in the recruitment process they will be bound by terms of confidentiality and this Privacy Notice.

If your application is successful and we make you an offer of employment, we will then share your data with:

former employers to obtain references for you
employment background check providers to obtain necessary background checks eg Occupational Health and the Disclosure and Barring Service to obtain criminal record checks (where required)

7 Your data protection rights

7.1 The law gives you a number of rights to control what personal information is used by us and how we can use it. Please see section 15 of the council’s Corporate Privacy Notice for further information.

7.2 Please be aware that your rights may differ depending on the lawful basis for processing your personal data.

7.3 The right to withdraw consent (if applicable). You can ask that we no longer use your details for this [processing/groups of processing]. If you wish to exercise this right, please contact the Data Protection Officer detailed in section 8.1 below.

You can choose what types of information, if any, to submit. Submitting your application information is voluntary. By submitting your data, you, the data subject, has given consent to the processing of your personal information for one or more specific purpose.

You are under no statutory or contractual obligation to provide data to the Council during the recruitment process. However, please be aware that if you decline, it will not be possible for your application to progress as we will be unable to process the data needed to do this.

The Council has a number of contracts with a third party suppliers and service providers eg Employment Agencies, who provide specialist services. These third parties will process applicant information in accordance with our instructions and make decisions regarding the information as part of the delivery of their services. They are also required to put in place appropriate security measures that ensure an adequate level of protection for personal information.

8 Who to contact

8.1 If you would like further information about how we use your personal information, or you wish to exercise one of your data rights or you wish to complain about the use of your personal information please contact the Data Protection Officer.

8.2 If you are still dissatisfied once you have contacted the Data Protection Officer, you have the right to complain to the ICO.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

9 Changes to this privacy notice

9.1 Privacy notices are live documents, which will be updated or revised in line with legislation.

Last updated 06 July 2023