What is the purpose of this notice?

The purpose of this notice is to tell you about how we use your data, and how we comply with data protection laws in connection with your interest in a role or contract with us (whether as an employee, worker or contractor).

When we carry out activities relating to hiring or engaging people, Board Intelligence acts as a "data controller" under the law. Put simply, this means that we are responsible for deciding how we hold and use personal information about you. We will hold some of your details as part of the hiring or contract making process. This notice makes you aware of how and why your personal data will be used, namely for the purposes of a recruitment or engagement exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK GDPR and the Data Protection Act 2018 (DPA).

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 interest in working with us, we may collect, store, and use the following categories of personal information about you:

  • Information you provide to us in your curriculum vitae and covering letter
  • Information provided (directly or indirectly) on an application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, or personal interests
  • Information provided by third parties such as your referee(s) (for example in a reference) or a credit agency
  • Details in connection with any vetting that we carry out (a DBS check for example)
  • Any information you provide to us during an interview (which may include your video in circumstances where we conduct an interview via video)
  • Any information provided to us through an online job site, via email/written correspondence, in person and/or by any other method
  • A record of your progress through any hiring process that we may conduct
  • Results of psychometric, aptitude or technical tests used as part of a selection process
  • We may also collect, store and use the following types of more sensitive personal information:
    • Information about your race or ethnicity or sexual orientation
    • Information about your health, including any medical condition, disabilities or vaccination status that we may need to know about (for example in order to facilitate fair access for you during a selection process)
    • Information about criminal convictions and offences
  • To the extent that you interact with our applicant tracking system (the ‘ATS’), details of your visits to the ATS website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to the ATS website and the resources that you access

How is your personal information collected?

We collect personal information in connection with our recruitment and hiring activities from the following sources:

  • You, the individual
  • Recruitment agencies, from which we collect the following categories of data: name, contact details (address, email, telephone number or digital equivalent), nationality, employment history, qualifications, interests, interview notes
  • Disclosure and Barring Service in respect of criminal convictions
  • Credit referencing/credit checking agencies
  • Your named referees, from whom we collect information about your previous employment, including dates, HR records, and their opinions on your performance (e.g. as provided in a reference), qualities and/or development needs
  • Via our ATS which provides us with the facility to link the data you provide to us with other publicly available information about you that you have published on the internet – this may include sources such as LinkedIn and other social media profiles. Our ATS also allows us to search various databases – some publicly available and others not, to find possible candidates to fill our roles, so we may obtain your personal data from these sources as well
  • A third party who recommends you as a candidate for a specific role or for our business more generally
  • The following data from third parties (e.g. universities or colleges) or publicly accessible sources such as LinkedIn and professional bodies (e.g. Law Society, ACAS, ACCA, BCS):
    • Details of professional qualifications
    • Details of interests/hobbies
    • Educational history and qualifications

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 or contract
  • Carry out background and reference checks, where applicable
  • Communicate with you about the recruitment/engagement 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 a role or contract since it would be beneficial to our business to appoint someone to that role. Where you apply for a role through our ATS, we rely on your consent, which is freely given by you during the application process, to disclose your personal data to Indeed Careers/Glassdoor Jobs on the basis described in the Data Sharing section below.

We also need to process your personal information to decide whether to enter into a contract with you.

We will use any details provided to us by you or a recruiter to take a decision on whether you are suitable for a current or future role or contract. We will then use these details to contact you in order to offer you relevant opportunities and/or to conduct a recruiting or contract-making process.

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 a 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 or your health to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview or otherwise
  • We may use information about your race or national or ethnic origin, your sexual life or sexual orientation, or disability status to support equal opportunity monitoring and reporting

Information about criminal convictions

We envisage that we will process information about criminal convictions. We may collect information about your criminal convictions history if we would like to offer you a role (conditional on checks and any other conditions, such as references, being satisfactory). We may carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. For example:

  • Where the role that you are applying for involves access to highly confidential data or requires a high degree of trust and integrity we will ask you to seek a basic disclosure of your criminal records history; or
  • If the role in question is one which is listed on the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (SI 1975/1023) and so is eligible for a check (standard or enhanced, in accordance with the Order) from the Disclosure and Barring Service.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Automated decision-making

We may use automation functionality within an ATS to select appropriate candidates for consideration based on criteria expressly identified by us, or typical in relation to the role for which you have applied to automate aspects of the process, however you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. Any decision as to who we will engage to fill the role will be made by our personnel.

Data sharing

Why might you share my personal information with third parties?

We will share your personal information with the following third parties for the purposes of processing your application: search consultancies, psychometric, aptitude or technical assessment providers, background, reference or credit checking services and our group companies and their personnel. Our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. Save as expressly set out in this notice, we do not allow our third-party service providers to use your personal data that we have shared with them for their own purposes. We only permit them to process your personal data that we have provided to them for specified purposes and in accordance with our instructions.

We may use information held about you to help our service providers (e.g. our ATS provider*) and third parties (such as a job sites through which you may have applied) to improve their services.

Where you have applied for a role opening through the 'Indeed Apply' functionality within our ATS, and where you have consented to this disclosure, we will disclose to Indeed certain personal data that we hold, including but not limited to a unique identifier used by Indeed to identify you, and information about your progress through our hiring process for the applicable role, as well as tangible, intangible, visual, electronic, present, or future information that we hold about you in our ATS, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). Indeed’s Privacy Notice in respect of Indeed’s use of the Disposition Data is available on Indeed’s website.

Where you have applied for a role through another service provider, we may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by us.

*We use an ATS provided by Workable Software Limited, a link to their privacy notice is available here.

Data security

We take data security seriously. We are ISO27001 and Cyber Essentials Plus certified and accordingly 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.

Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

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.

Data retention

How long will you use my information for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period if it relates to a complaint or in connection with our legal rights or obligations. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, together with any applicable legal, regulatory, tax, accounting or other requirements.

Unless we have a specific reason (as described above) to keep your data, we will not retain it for longer than three years without your consent. If you would like us to retain your personal information on file for longer than this (e.g. to consider you for future roles), please provide written confirmation of this to us and we will keep your data on file for up to five years (noting that at any time during this period, you may withdraw your consent and ask us to remove your details from our records) for this purpose. Where you do confirm that you would like us to keep your data on file for longer than three years, we would ask that if any of your details change (e.g. your address), that you let us know so that we can keep your records up to date.

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
  • 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 a member of the Board Intelligence HR team, via hr@boardintelligence.com
  • Right to withdraw consent. To the extent that we have relied upon your consent to process any of your personal information for the purposes of the recruitment exercise, please note that you have the right to withdraw your consent to the processing for that purpose at any time. To withdraw your consent, please contact hr@boardintelligence.com. Once we have received notification that you have withdrawn your consent, subject to any rights that we may have, we will no longer process the applicable personal information and we will proceed to dispose of your personal data securely

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this notice. If you have any questions about this notice or how we handle your personal information, please contact the DPO via: info@boardintelligence.com, by telephone on +44 (0)207 192 8218, or by post at 24 Cornhill, London, EC3V 3ND. 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.

Last updated: 27th February 2023
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