1.Introduction

1.1     This policy tells you about how Charles Taylor Group  (“Charles Taylor”) handles personal data of candidates applying for employment with Charles Taylor (referred to as Candidate Data). We recognise the importance of the correct and lawful processing of personal data in maintaining confidence in our operations.

1.2     When collecting and processing Candidate Data, Charles Taylor is acting as a “data controller” of that data. That means that Charles Taylor is responsible for deciding how we collect, store and process your Candidate Data.

2. Data we collect

2.1     The Candidate Data we generally hold and process includes:

• Your name and contact details
• Date of birth
• Information in your CV about your skills, background, experience, qualifications or personal interests
• Any salary expectations or other information you have shared

2.2     The Candidate Data you provide to us may include special category personal data which might include information about your medical history, race, ethnicity, sexual orientation, religious beliefs, trade union membership, genetic and biometric data, political opinions, and any other physical or mental health details.

3. Purposes of collecting data

3.1     The Candidate Data you provide in your application and obtained as part of the recruitment process will only be processed to facilitate the recruitment process for the particular position you have applied for, or for any suitable future vacancies if you have agreed to us contacting you for that purpose. Your Candidate Data may be used to assess your application for employment at Charles Taylor, conduct reference checks and to inform you of further career opportunities. 

3.2     In the event of your application resulting in an offer and your acceptance of a position at Charles Taylor, the data collected will become part of your employment record and will be used for employment purposes.

4. Why do we process your Candidate Data?

4.1     Under the GDPR, a data controller should only collect your personal data if it has a valid purpose for doing so that falls into one of the prescribed categories set out in the GDPR. The purposes for which we process your data are set out below.

Charles Taylor requires personal data about you in order to take steps to enter into a contract with you and will retain that personal data in order to perform that contract.

Charles Taylor has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process.

Your Candidate Data allows us to manage the recruitment process, assess and confirm your suitability for employment and decide whether to offer you a position. We may also need to process data from job applicants to respond to and defend against legal claims.

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts.

We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.

Where we need to process other special categories of data, such as information about ethnic origin, sexual orientation, or disability, this is for equal opportunities monitoring purposes as permitted by the Data Protection Act 2018. This information will be collected and held on an anonymised basis.

4.2     For some roles, we will 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 to establish whether or not an individual has committed an unlawful act or been involved in dishonesty or other improper conduct.

4.3     Where it is necessary to collect and process any special categories of sensitive personal data, we will ensure it is handled with the utmost discretion and will limit access to the information to the individuals who require it for the purposes of which it is being requested / processed.

4.4     If you have any questions as to why we hold any type of personal data about you, please contact the Charles Taylor Group DPO or your contact in the Charles Taylor recruitment team.

4.5     Where we rely on our legitimate interests as our lawful basis for processing, we will always balance them against your rights and freedoms. Where your rights override our legitimate interests, we will cease to process your Candidate Data.

4.6     We obtain Candidate Data from you, and we may also receive information about you from other companies and individuals, such as your previous employer, referees or recruitment agencies. We may also share Candidate Data with these same people, but we can only do this in accordance with the law. Any third parties to whom we pass personal data are also required to comply with data protection laws.

4.7     In some cases where it is necessary for the purposes of considering your application, your Candidate Data may be transferred to and processed in other countries, including the US, which are not deemed to provide the same level of data protection as your home country. We will always keep a record of where your data has been sent outside of the UK and European union and you can request information about where we transfer your Candidate Data if you wish.

5. Storage of your Candidate Data

5.1     We will store your Candidate Data in a number of places, including in our recruitment files, in our HR system, and in other IT systems (including our email system).

6. Retaining information

6.1     In addition to using Candidate Data for the position for which you have applied, Charles Taylor may retain and use your Candidate Data to consider you for other positions.

6.2     Unless required for tax or other legal purposes or in connection with employment as specified above, Candidate Data will be retained for a maximum of one year (or less where required by law). If you have provided your consent, then your data will be held for up to two years for the purposes of contacting you to tell you about new opportunities that may be of interest to you.

7. If you fail to provide information

7.1     If you fail to provide certain personal data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application further. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

8. Asking for information we hold about you  

8.1     You have various legal rights in respect of your Candidate Data including the right of:

• Information and access to your data, including a “portable” copy of your data;
• Erasure and rectification of your data; and
• Rights to restrict or object to processing of your personal data.

8.2     Where we rely on your consent to process your personal data you can withdraw that consent at any time. To exercise these data subject rights, please make a request in writing, giving your full name and address. You should send your request to:

Emma Hancock
Charles Taylor Group Data Protection Officer
Email: DPO@charlestaylor.com
Address: 2 Minster Court, Mincing Lane, London EC3R 7BB England

8.3     We aim to comply with requests for access to personal data as quickly as possible. We will ensure that we deal with requests within 30 days of receipt unless there is a good reason for delay.

Normally you can see all the information we have, but there are some exceptions. These exceptions mainly relate to the way that crime is detected or prevented, catching or prosecuting offenders, and assessment taxes or duty.

Last reviewed: June 2023