Recruitment and Selection Privacy Notice
1. Introduction
Vida Bank Limited (Vida) is committed to being transparent about how it collects and uses data, and to meeting its data protection obligations. We take your privacy very seriously. This notice explains how Vida Bank Limited (referred to in this notice as (we, us, Vida or our) is known as the ‘controller’ and collects and uses information during the recruitment and selection process.
This Privacy Notice provides guidance to All ‘candidates/Applicants’ of Vida vacant roles. Any reference in this notice to you or your refers to anyone whose personal information we process.
This Privacy Notice is to inform you about:
- What personal information is;
- How we collect your personal information;
- The types of personnel information we collect;
- How we use your personal information;
- The Legal basis for processing your personal information;
- What will happen if you do not provide the information which we request;
- How we share your personal information;
- How long we keep your personal information;
- How we keep your personnel information secure;
- What will happen if you email us;
- Overseas transfer of your personnel data;
- Your rights in relation to your personnel information;
- How to make complaints in relation to your personnel information; and
- How to contact us.
The table at the end of this notice provides an overview of the data that we collect, the purposes for which we use that data, the legal basis which permits us to use your information and the rights that you have in relation to your information.
Any references to personnel information in this privacy notice will include personal data, and where relevant, special categories of personal data.
Any reference to Group
means Vida Bank Limited and its associated companies as defined by the Companies Act 2006.
We will treat all of your personal information as confidential and in accordance with the Data Protection Legislation and your personnel information will only be shared with others in accordance with this privacy notice.
2. What is personal information?
Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, medical information and bank account details.
3. How do we collect personal information?
We collect personal data about you from various sources including:
- from you when you contact us directly through the recruitment and onboarding process;
- from the recruitment agency representing you during your application, recruitment and onboarding process; and
- from other people when we check references or carry out background checks – if we do this, we will inform you during the recruitment process of the exact checks that are carried out and this will usually only be required once a job offer is made.
4. What personal information do we collect?
We collect the following categories of information about you:
- Personal contact details such as name, date of birth (if disclosed), title, address, telephone number and personal email addresses;
- Recruitment information (including copies of right to work documentation, references and other information in your CV or cover letter or otherwise provided as part of the application process such as qualifications, skills and employment history);
- Information about criminal convictions and offences committed by you and any other checks as required for your role, for example, but not limited to, directorship searches, adverse media, credit checks;
- Information about any conflicts of interest you might have with Vida; and
- Whether you have a disability for which Vida needs to make reasonable adjustments during the recruitment process.
5. How do we use your information?
We use your information for the following purposes:
- To make decisions about your recruitment and appointment;
- To check you are legally entitled to work in the UK;
- To assess your qualifications for a particular job or task;
- To conduct data analytics studies to review and better understand job application rates.
6. What is the legal basis of our data processing?
Under data protection legislation we are only permitted to use your personal data if we have a legal basis for doing so as set out in the data protection legislation. We rely on the following legal bases to use your information for employment/engagement related purposes:
- Where we need information to enter into a contract with you
- Where we need to comply with a legal obligation e.g. right to work documentation
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
The table at the end of this notice provides more detail about the information that we use, the legal basis that we rely on in each case and your rights.
Some information is classified as "special" data under data protection legislation. This includes information relating to racial or ethnic origin, religious beliefs or political opinions, sexual orientation. This information is more sensitive, and we need to have further justifications for collecting, storing and using this type of personal data. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data. We may process special categories of personal data and criminal conviction information in the following circumstances:
- In all circumstances with your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent;
- We will use information about your physical and mental health or disability status to comply with our legal obligations, including to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits; and
- We will use information about your race or ethnic origin, religious or philosophical beliefs, or sexual orientation to ensure meaningful equal opportunity monitoring and reporting – the legal basis of this processing is that it is in the public interests to carry out diversity monitoring as permitted by the Data Protection Act 2018.
- Data that Vida uses for these purposes is collected with the express consent of the individual, which can be withdrawn at any time by contacting the HR Department. You are free to decide whether to provide such data.
If your application is unsuccessful, Vida will keep your personal data on file in case there are future employment opportunities for which you may be suited. The timeframe that this data will remain on file as detailed in the Retention and Destruction Policy is 12 months. You can request this remains on file for longer should you wish. You are free to withdraw your consent at any time by contacting the HR department at hradmin@vidabank.co.uk
7. What happens if you do not provide information that we request?
We need some of your personal data in order to conduct the recruitment and selection process. If you do not provide such information, we may not be able to continue with the recruitment process or offer you employment/engagement. We explain when this is the case at the point where we collect information from you.
8. How do we share your information?
We share your personal data in the following ways:
- Where we use third party service providers who process personal data on our behalf in order to provide services to us. This includes through an Applicant Tracking System (ATS), recruitment agents and IT systems providers and checking services and references.
- We will share your personal data with third parties where we are required to do so by law or to comply with our regulatory obligations.
- With other entities in our group as part of our regular reporting activities and in the context of a business reorganisation or group restructuring exercise.
- If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers.
Where we share your personal data with third parties, we ensure that we have appropriate measures in place to safeguard your personal data and to ensure that it is solely used for legitimate purposes in line with this privacy notice.
9. For how long do we keep your information?
As a general rule we keep personal data about candidates for the duration of the recruitment and selection process and for a period of 12 months after candidates have been notified whether their application has been successful. However, where we have statutory obligations to keep personal data for a longer period or where we may need your information for a longer period in case of a legal claim,
then the retention period may be longer. Full details of the retention periods that apply to your information are set out in our Record Retention & Destruction Policy which is available upon request from the HR department. For successful candidates, employee files are retained for 6 years after employment ceases.
10. How do we keep your information secure?
Vida takes the security of your data seriously. The organisation has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email). Data is encrypted as it moves between the sender and the data centre. All personal identifiable information that is uploaded to our online Workspace can be monitored. The following security tools are applied and available within Vida’s Workspace offering:
- Encryption of Data in Transit
- Encryption of Data at Rest
- Virus Detection
- Control Access Based on Network Location (Optional)
- Ability to Manage/Restrict Parties
- Access, Permission, and Sharing
Where we engage third parties to process personal data on our behalf, we do so on the basis of written instructions, and they are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
11. Transferring your personal information overseas?
We may transfer, store, or process your personal information in locations outside the UK and the European Economic Area (EEA). Where the countries to which your personal information is transferred do not offer an equivalent level of protection for personal information to the laws of the UK, we will ensure that appropriate safeguards are put in place.
If you would like to see a copy of the adequacy mechanisms that we use to protect your personal data, please contact dataprotectionoffice@vidabank.co.uk
12. Your rights in relation to your personal information
You have a number of rights in relation to your personal information, these include the right to:
- be informed about how we use your personal information;
- obtain access to your personal information that we hold;
- request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate;
- request that we erase your personal information in the following circumstances:
- if Vida is continuing to process personal data beyond the period when it is necessary to do so for the purpose for which it was originally collected;
- if Vida is relying on consent as the legal basis for processing and you withdraw consent;
- if Vida is relying on legitimate interest as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing;
- if the personal data has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation);
- if it is necessary to delete the personal data to comply with a legal obligation.
- ask us to restrict our data processing activities where you consider that:
- personal data is inaccurate;
- our processing of your personal information is unlawful;
- where we no longer need the personal information, but you require us to keep it to enable you to establish, exercise or defend a legal claim;
- where you have raised an objection to our use of your personal information;
- request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to take steps to enter into a contract with you and personal information where we are relying on consent to process your personal data;
- object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection, we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and
- not be subject to automated decisions which produce legal effects, or which could have a similarly significant effect on you.
If you would like to exercise any of your rights or find out more, please contact dataprotectionoffice@vidabank.co.uk. The table at the end of this notice provides more detail about the information that we use, the legal basis that we rely on in each case and your rights.
13. Complaints
If you have any complaints about the way we use your personal information, please contact dataprotectionoffice@vidabank.co.uk who will try to resolve the issue. If we cannot resolve your complaint, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK). Should you require more information from your local data protection authority please visit www.ico.org.uk
14. Contact details
If you have any questions, comments or requests regarding any aspect of this privacy notice, please do not hesitate to contact us by sending a letter or an email.
Please email us at dataprotectionoffice@vidabank.co.uk
15. Quick check of how we use your personal data
RECRUITMENT DECISIONS
Data used: Personal contact details, recruitment information, employment/engagement records, and compensation history.
Legal basis: Legitimate interests. It is in our legitimate interests to evaluate whether you have the necessary skills and qualities to perform the relevant role.
RIGHT TO WORK CHECKS
Data used: Information relating to your right to work status, national insurance number, passport number, nationality, tax status information, and personal contact details.
Legal basis: Legitimate interest. It is in our interests to ensure that those who work for us have the right to work in the UK as well as to establish the statutory excuse to avoid liability for the civil penalty for employing someone without the right to undertake the work for which they are employed.
FRAUD, CRIME PREVENTION, CREDIT CHECKS
Data used: Information about criminal convictions and offences committed by you. Identity verification information. Credit checks
Legal basis: Public interest and legitimate interest. It is in our interests as well as the interest of our candidates/ employees/ workers/ contractors to ensure the prevention of fraud and crime is monitored. This will ensure a safe workplace for all.
DIVERSITY MONITORING
Data used: Gender, marital status and dependents and information about your race or ethnicity, religious beliefs, health and disabilities, sexual orientation.
Legal basis: Public interest.
TO DEAL WITH LEGAL DISPUTES
Data used: Personal contact details, references, information submitted as part of the selection process and interview notes.
Legal basis: Legitimate interest. It is in our interests to process personal data to make and defend legal claims to ensure that our legal rights are protected.
Which rights apply to all of the above?*
The generally applicable rights plus the right to object.
*The following generally applicable rights always apply: right to be informed, right of access, right to rectification, right to erasure, right to restriction and rights in relation to automated decision making. For more details about your rights and how to exercise them, please see 'your rights in relation to your personal information'.
