Orbit Recruitment Privacy Policy Introduction Orbit are the controllers of the information ( personal data ) that we collect about you, our data subjects, which means we are responsible for how your data is processed. The word process covers what can be done with personal data, including collection, storage, use, sharing and deletion. This privacy notice explains why and how we process your personal data, and explains the rights you have, including amongst others, the right to access your data, and to object to the way it is processed. Please see the section on Your rights as a data subject for more details on your rights and how to exercise them. Who collects the information Orbit is made up of Heart of England Housing Association Ltd, Orbit South Housing Association Ltd, Orbit Home (2020) Ltd, Orbit Treasury Ltd, Orbit Capital Plc, and is known as Orbit Group Ltd ( Company ) is a data controller and gathers and uses certain information about you. In this notice, references to we or us will mean the all Orbits legal entities. Data protection principles We will comply with the data protection principles when gathering and using personal information, as set out in our Data Protection Policy. Our contact details are: Address: Garden Court, Harry Weston Road, Binley Business Park, Coventry, CV3 2SU Email: HRSC@orbit.org.uk Telephone number: 0247 643 8000 If you have any queries about this notice or anything related to data protection, you can contact our Data Protection Officer (DPO) at Garden Court, Harry Weston Road, Binley Business Park, Coventry, CV3 2SU, Rebecca Kay on Informationgovernance@orbit.org.uk or by telephone on 0247 643 8044. Personal data Personal data is any information that relates to a living, identifiable person. This will usually include your name, address, contact details, and other information we collect as part of our relationship with you. 1
It can also include special categories of data, which is the official term for information about a person s race or ethnic origin, religious, political or other beliefs, physical or mental health, trade union membership, genetic or biometric data, sex life or sexual orientation. The use of this type of data, and of information about criminal convictions and offences, is subject to strict legal controls. We only process data if we need to for a specific purpose, as explained below. Most often, we collect your personal directly from you, through our contact with you. We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it. How and where we store your data Your personal data is held in both hard copy and electronic formats. Electronic data, including emails, is stored on our servers, which are located in the UK on our software suppliers servers. Who we share your data with We may also need to share some of the categories of personal information set out in the Schedule with other parties, such as external contractors, our professional advisers and potential purchasers of some or all of our business or on a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information as required to comply with the law. How long we keep your data If successful we keep your information during and after your employment for no longer than is necessary for the purposes for which the personal information is processed. Some of our retention periods are based on legal requirements, and others are based on the practical reasons we need to keep the data for a certain period of time. Once we reach the retention period, we will securely delete the relevant data, unless we are legally required to keep it longer, or there are legal reasons why we should keep it longer. Unsuccessful applications are destroyed / deleted after 12 months. Your rights as a data subject As a data subject, you have the following rights in relation to your personal data: 2
To be informed about how your data is handled; To gain access to your personal data; To have errors or inaccuracies in your data changed; To have your personal data erased, in limited circumstances; To object to the processing of your personal data for marketing purposes or when the processing is based on the public interest or other legitimate interests; To restrict the processing of your personal data, in limited circumstances; To obtain a copy of some of your data in a commonly used electronic form, in limited circumstances; Rights around how you are affected by any profiling or automated decisions. If you wish to exercise any of these rights, please contact us. You can contact any colleague, or our Data Protection Officer (DPO) Rebecca Kay on Informationgovernance@orbit.org.uk Withdrawing consent If we are relying on your consent to process your data, you may withdraw your consent at any time by contacting us. Keeping your personal information secure We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. How to complain You have the right to complain about the way in which we process your personal data. In the first instance contact our Data Protection Officer, Rebecca Kay to resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint. Automated decision-making Recruitment processes are not based solely on automated decision-making. 3
Your data information we collect and hold Orbit processes your data so we can manage and support our relationship with you, comply with legal obligations, improve our services and achieve our legitimate business aims. The table set out in the Schedule below summarises the information we collect and hold, how and why we do so, how we use it and with whom it may be shared. The Schedule About the information we collect and hold and the legal basis The information we collect How we collect the information Why we collect the information How we use and may share the information Your name, contact details (ie address, home and mobile phone numbers, email address) and emergency contacts (ie name, relationship and home and mobile phone numbers) From you Application Form Psychometric Tests To enter into/perform the employment contract Legitimate interest: to maintain employment records and good employment practice To enter into/perform the employment contract; transparent recruitment and selection of candidates to vacancies, to comply with legal obligations and Equal Opportunities. Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs From you Application Form legal obligations and for reasons of substantial public interest (equality of opportunity and/or treatment) equal opportunities monitoring obligations and to follow our policies For further information, see * below 4
Criminal records information, including the results of Disclosure and Barring Service (DBS) checks From you, Application Form and the DBS To perform the employment contract legal obligations For reasons of substantial public interest, including safeguarding Orbits customer s inline with the Care Quality Commission standards. To carry out statutory checks in line with the job role Information shared with HR, DBS and other regulatory authorities as required Information in applications you make for other positions within our organisation From you Application Form To enter into/perform the employment contract legal obligations Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice To process the application, to enter into/perform the employment contract; transparent recruitment and selection of candidates to vacancies, to comply with legal obligations and Equal Opportunities. Information shared with relevant managers, HR personnel 5
You are required (by law or under the terms of your contract of employment, or in order to enter into your contract of employment) to provide the categories of information marked above to us to enable us to verify your right to work and suitability for the position, to pay you, to provide you with your contractual benefits such as pension scheme. * Further information on the monitoring we undertake in the workplace and how we do this is available in our Equality & Diversity Policy, available on the company website. 6