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Privacy Notices

Privacy Notices – Direct & Indirect

 

The General Data Protection Regulation (GDPR) requires organisations to be more transparent with individuals about the personal data they hold, why they hold it and what they plan to do with it. To do this, data controllers (us) must provide specific information to data subjects (candidate/individual) when first collecting their personal data – this is known as ‘transparency information’.

 

One of the ways to provide this information is through a Privacy Notice. This can be sent on paper or electronic form e.g. by PDF or email and does not require the individuals signature.

 

When to give Privacy Notice information

 

Direct - Where you collect the personal data from the individual you should give him or her the transparency information when you first collect the personal data.

 

  1. Mark file RAW Direct
  2. Once you have received an application for work and you have contacted/established that you would like to provide the applicant with work-finding services you will need to send them the Registration Pack and the DIRECT Privacy Notice.
  3. If you find that you do not have suitable work for them at this stage but want to keep the CV on file – send them a Privacy Notice and mark the file for review in ONE YEAR – application will remain in RAW until the recruitment process starts again.
  4. If the candidate is unsuitable or a duplicate application and you feel that you are unable to help this candidate, then add a note to the journal and mark for DELETION

 

Privacy Notice (Direct)

 

Indirect

  • Where you do not collect the personal data from the data subject (e.g. where you collect it from a third party such as a jobs board) - you should give the individual the transparency information no later than one month after you collected the data, or when you first communicate with the data subject if that is before one month expires.

 

  • If you disclose the personal data to a third party and that disclosure happens before the one month expires, then you must give the transparency information no later than the first disclosure.

 

 

Privacy Notice (Indirect)

 

 

  1. Mark files RAW Indirect
  2. Once you have identified an individual’s CV and you have established that you would like to provide them with work-finding services you will need to provide them with the Privacy Notice (Indirect) ideally at the time of the first communication;
  3. If the response is positive, then you will send this along with the registration pack and continue with the registration process as normal.
  4. If you fail to contact them immediately, you will need to send the notice at the latest within one month of obtaining that CV.
  5. If the response is negative, then at this stage clarify with them if they would like to be considered for other roles in the future i.e keep the CV on file – send them a Privacy Notice and mark the file for review in ONE YEAR – application will remain in RAW until the recruitment process starts again
  6. If the candidate response is negative, then this file will need to be marked for DELETION

Note: If you intend to send the CV onto a 3rd party, then the Privacy Notice should be sent at first disclosure.

 

 

At all times when considering when to provide the transparency information, you must consider the reasonable expectations of the individual, the effects the processing will have on him or her and the individual’s ability to exercise his or her rights.

 

Importantly, accountability requires transparency across the whole processing life cycle and not just at the initial point of contact, so you must tell individuals about any changes to processes or privacy notices.

 

How we do this in Influence

Direct Applications

Login to Influence

Select the candidate

Select the Email Icon

Select the relevant Type – which will contain your candidate registration email (e.g. Candidate Reg Template)

 

 

Select Temp – to insert the registration pack – the Privacy Notice will be included in this ‘pack’

Send the template email and the attachments to the candidate

 

Indirect

Login to Influence

Select the candidate

Select the Email Icon

Select the Type – GDPR – Data Protection Entry

Select Temp – INPN (indirect privacy notice)

 

Send the template email with the attachment to the candidate

The Company shall provide information on action taken or not taken with regards to the individual data protection rights without undue delay and in any event within one month of receipt of the request

 

 
+44 (0) 203 008 8636