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).
We will comply with data protection law and principles, which means that your data will be:
In connection with your interest in working with us, we may collect, store, and use the following categories of personal information about you:
We collect personal information in connection with our recruitment and hiring activities from the following sources:
We will use the personal information we collect about you to:
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 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.
We will use your particularly sensitive personal information in the following ways:
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:
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
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.
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.
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.
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.
Under certain circumstances, by law you have the right to:
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: email@example.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