JOB APPLICANT & RECRUITMENT PRIVACY NOTICE

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1. Introduction and Purpose

As part of our recruitment processes, Home at Peace Ltd collects and processes personal data relating to job applicants. We are committed to being transparent about how we handle that data, protecting your privacy, and meeting our data protection obligations under the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

Because we are a Care Quality Commission (CQC) regulated domiciliary care provider, we are legally required to verify specific robust information before allowing individuals to deliver care to our vulnerable service users.

2. Who is the Data Controller?

Home at Peace Ltd is the data controller for the information you provide during the recruitment process unless otherwise stated.

  • Data Controller: Home at Peace Ltd
  • Office Address: 5 Brayford Square, London, E1 0SG
  • Data Protection Officer (DPO): Carol Henry
  • Operational Oversight: Carol Henry (Registered Manager)
  • Contact Number: 0207 870 8162

3. What Information Do We Collect?

We collect, store, and process a variety of information about you throughout the application pipeline. This includes:

  • Identity Data: Your name, address, email address, telephone number, and personal contact details.
  • Application Data: Details of your qualifications, skills, employment history, experience, and professional training.
  • Interview Records: Information from assessments, interview notes, or telephone screenings.
  • Right to Work Data: Documentation confirming your identity and legal right to work in the UK (e.g., passport, visa status).

3.1 Special Category (Sensitive) Data

Due to the nature of health and social care recruitment, we are legally required to collect “Special Category” and criminal offense data:
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  • Health and Medical Data: Information about your physical or mental health, including pre-employment health questionnaires, to assess your fitness to work and determine any reasonable adjustments required under the Equality Act 2010.
  • Criminal Records Data: Enhanced Disclosure and Barring Service (DBS) check information, police checks, or self-disclosures. This is mandatory under care regulations to ensure safe recruitment practices.

4. How Do We Collect Your Data?

We collect your personal data in a variety of ways:

  • Directly from you via application forms, CVs, or covering letters.
  • Through identity documents like your passport or driving licence.
  • Through interviews, tests, or other forms of assessment.
  • From third parties, such as your named professional referees, employment agencies, or the Disclosure and Barring Service (DBS) for criminal record tracking. We will only seek third-party information once an official conditional job offer has been extended to you.

5. Why Do We Process Personal Data? (Lawful Basis)

We process your personal data under the following lawful bases defined by UK GDPR:

  • Contractual Intention: To take necessary steps at your request prior to potentially entering into an employment contract with you.
  • Legal Obligation: To comply with statutory requirements, such as checking your legal right to work in the UK or meeting the strict vetting standards demanded by the CQC for domiciliary care staffing.
  • Legitimate Interests: To manage our recruitment processes effectively, defend against legal claims, and ensure we recruit the highest quality staff to deliver safe care services.
  • Special Category Conditions: We process health and criminal record data under UK GDPR Article 9(2)(b) (Employment and Social Security Law) and the Data Protection Act 2018 (Schedule 1, Part 1) to fulfil our regulatory duties to safeguard vulnerable service users.

6. Who Has Access to Your Data?

Your information will be shared internally strictly for the purposes of the recruitment exercise. This includes:

  • Members of the HR and recruitment team.
  • Interviewers and supervisors involved in the selection process.
  • The Registered Manager and executive directors.

We will not share your data with external third parties during the initial application process unless your application is successful and we make you a conditional offer of employment. At that stage, we will share your data with:

  • Former employers or educational bodies to obtain mandatory professional references.
  • The Disclosure and Barring Service (DBS) to process your background check.
  • Occupational health providers if a specific medical assessment is required for field work.
  • The Home Office or processing agents to verify your right to work documentation.

We do not transfer your recruitment data outside the United Kingdom.

7. How Do We Protect Your Data?

We take data security very seriously. Home at Peace Ltd has internal controls, firewalls, and data protection policies in place to ensure that your data is not lost, accidentally destroyed, misused, or disclosed unlawfully.

  • Digital Files: Securely stored within our cloud-based HR and recruitment applicant tracking software, protected by restricted user permissions and multi-factor authentication.
  • Physical Files: Any printed application materials are kept in locked filing cabinets inside the Registered Manager’s secure office.
  • Access to recruitment folders is strictly limited to individuals who require the data to perform their job duties.

8. How Long Do We Keep Your Data?

  • Unsuccessful Candidates: If your application for employment is unsuccessful, Home at Peace Ltd will hold your personal data on file for 6 months from the date the recruitment decision was communicated to you. At the end of that period, your digital records will be permanently deleted and any physical paperwork will be cross-cut shredded.
  • Successful Candidates: If your application is successful, the personal data gathered during the recruitment process will be transferred to your permanent electronic Personnel File and retained in accordance with our standard Employee Data Retention Schedule.

9. Your Rights Under UK GDPR

As a data subject, you have several legal rights regarding your information. You can:

  • Access: Request a copy of the personal data we hold about you by submitting a Subject Access Request (SAR) to Francesca Baker.
  • Rectify: Request that we correct any inaccurate or incomplete data.
  • Erase: Request that we delete your data (the “Right to be Forgotten”), subject to our legal record-keeping obligations.
  • Restrict: Ask us to restrict the processing of your data under certain conditions.
  • Object: Object to the processing of your data where we are relying on legitimate interests as our legal grounds.

If you wish to exercise any of these rights, please contact our Data Protection Officer. If you believe that Home at Peace Ltd has not complied with your data protection rights, you have the right to lodge a formal complaint with the Information Commissioner’s Office (ICO) (ico.org.uk).