TRL Ltd is a company incorporated in England and Wales, 3142272 and whose registered address is Crowthorne House, Nine Mile Ride, Wokingham, Berkshire, RG40 3GA.
As part of any recruitment process, the organisation collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
1. The personal data we may like to collect from you is:
- your name, address and contact details, including email address and telephone number.
- details of your qualifications, skills, experience and employment history
- information about your current or previous level of remuneration
- whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process
- information about your entitlement to work in the UK
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.
- Information about criminal convictions and offences
The organisation collects this information in a variety of way;. For example, data might be contained in application forms, CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
The organisation may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. The organisation will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
2. Purpose and legal basis for processing your Data
The organisation needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.
The organisation has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.
Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
The organisation processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where the organisation processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.
For some roles, the organisation is obliged to seek information about criminal convictions and offences. Where the organisation 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.
The organisation will not use your data for any purpose other than recruitment.
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
The organisation will not transfer your data outside the European Economic Area.
3. Storage & Disposal
The organisation takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. Our Applicant Tracking Software is provided by Access UK Ltd and your information is stored within the Telehouse Data Centre in London & back-up data is stored in the Equinix Data Centre in Slough. Access UK Ltd have access only for support purposes with our agreement and they manage the Data Centre Infrastructure. They are Certified ISO27001:2013 and have confirmed their own GDPR compliance.
TRL may keep your personal data on file for a period of up to 12 months to ensure compliance with any legislative and regulatory requirements.
Your data will not be transferred out of the EEA. Any change to that storage will be communicated to you.
4. Principles and Rights
TRL will comply with data protection law, which means the personal information we hold about you must 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.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require the organisation to change incorrect or incomplete data;
- require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and
- ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation's legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact email@example.com.
If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.
5. What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.
6. Complaints and Contact Information
Our Data Protection Manager can be contacted at firstname.lastname@example.org. TRL may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
If you feel we have not processed your data in accordance with the Principles and Rights of the individual under GDPR, you are at liberty to raise a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
You are also able to raise a complaint with the Information Commissioners Office