CAREERS PRIVACY NOTICE
1 THIS NOTICE
1.1 This notice is provided by Rentokil Initial 1927 plc whose registered office is Riverbank, Meadows Business Park, Camberley GU17 9AB and its subsidiaries (“we”, “us” or “our”) and is addressed to individuals who are applying for a job with us (“you”). It applies during the employment application process and for the period specified in the notice after the end of the application process.
1.2 This notice relates to personal information about you from which you can be identified. We refer to this information throughout this notice as “personal data”. There are also “special categories” of more sensitive personal data, such as relating to health or ethnic origin, which require a higher level of protection. Personal data does not include data where the identity has been removed (anonymous data). Section 3 of this notice sets out examples of your personal data that we use.
1.3 This notice sets out how we collect and process your personal data. It also provides certain information that is legally required and lists your rights in relation to your personal data. Please read this notice carefully, so that you are aware of how and why we are using your personal data.
1.4 We are a controller of your personal data. This means that we are responsible for deciding how we hold and use personal data about you. As a controller we use (or ‘process’) the personal data we hold on you in accordance with this notice.
1.5 We take our data protection responsibilities seriously and this notice reflects the obligations set out in the General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”) and any laws in your region giving effect to its provisions.
1.6 If you need to contact us in connection with our processing of your personal data, then you can do so by contacting our Data Protection Officer by email at email@example.com or by post to: Data Protection Officer, Rentokil Initial 1927 plc, Riverview Meadows Business Park, Blackwater, Camberley, Surrey GU17 9AB.
1.7 Your personal data belongs to you and it is your choice whether you provide us with your personal data. However, if you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for the role you are applying for and you fail to provide us with relevant details, we will not be able to take your application further.
1.8 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
1.9 This notice may be amended or updated from time to time and we would recommend that you regularly check it to review and remind yourself of the contents of it.
2 PRINCIPLES OF DATA PROTECTION
2.1 We will comply with data protection law and principles, which means that your data will be:
2.1.1 Used lawfully, fairly and in a transparent way;
2.1.2 Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
2.1.3 Relevant to the purposes we have told you about and limited only to those purposes;
2.1.4 Accurate and kept up to date;
2.1.5 Kept only as long as necessary for the purposes we have told you about; and
2.1.6 Kept securely.
3 PERSONAL DATA
3.1 In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
3.1.1 The information you have provided to us in your curriculum vitae and covering letter;
3.1.2 The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications and your preferred language;
3.1.3 Any information you provide to us or gathered during an interview;
3.1.4 Recommendations provided on your behalf by others.
3.2 Where permitted by law we may also collect, store and use the following "special categories" of more sensitive personal information:
3.2.1 Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions for purposes of government reporting where required, as well as to understand the diversity characteristics of the Rentokil Initial workforce;
3.2.2 Information about your health, including any medical condition, health and sickness records where it is relevant to your ability or availability to work or to a workplace accommodation, subject to legal limits on the timing of collection of such data and other applicable limitations;
3.2.3 Where applicable, information about your credit history, criminal convictions and offences.
4 SOURCES OF PERSONAL DATA
4.1 We may obtain your personal data from various sources including the following:
4.1.2 Other entities within our corporate group;
4.1.3 Providers of background and other checking and vetting services, including Disclosure Scotland, the Disclosure and Barring Service and credit reference agencies;
4.1.4 Statutory or other official bodies such as the Home Office;
4.1.5 Our careers application portal and websites;
4.1.6 Recruiters including employment agencies;
4.1.7 Relevant taxation / governmental authorities;
4.1.8 Credit Reference Agency;
4.1.9 Past employers;
4.1.11 Psychometric Testing Partners currently being Cubiks;
4.1.12 Public sources including social media.
5 HOW WE WILL USE INFORMATION ABOUT YOU AND OUR LAWFUL BASES FOR PROCESSING YOUR DATA
5.1 We will use the personal information we collect about you to:
5.1.1 Assess your skills, qualifications, and suitability for the role;
5.1.2 Carry out background and reference checks, where applicable;
5.1.3 Communicate with you about the recruitment process;
5.1.4 Keep records related to our hiring processes;
5.1.5 Comply with legal or regulatory requirements.
5.2 When you apply for a role, we process your data on the basis of our legitimate interests for ensuring that we recruit appropriate employees to our business and to decide whether to enter into a contract of employment with you.
5.3 Having received your application and where applicable your CV, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will then decide whether to invite you for an interview based on the contents of your CV and the skills and experience needed for the role. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and where required will carry out a criminal record and / or credit reference check before confirming your appointment.
6 HOW WE WILL USE SPECIAL CATEGORIES OF DATA
6.1 Where we process special categories of data, we shall do so on only in accordance with the law and in the following ways:
6.1.1 We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview;
6.1.2 We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
7 DATA RELATING TO CRIMINAL CONVICTIONS
7.1 We will only collect and hold information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so.
7.2 We will only use data relating to criminal convictions where the law allows us to - this will usually be where processing is necessary in order to carry out our obligations in connection with your employment. Less commonly, we may use data relating to criminal convictions:
7.2.1 where it is necessary in relation to legal claims;
7.2.2 where you have already made the information public; or
7.2.3 to protect your vital interests (or someone else’s interests) and you are not capable of giving your consent or we cannot reasonably be expected to obtain your consent.
8 RECIPIENTS OF PERSONAL DATA
8.1 We choose our service providers carefully and require them to take appropriate security measures to protect your personal data. As part of the recruitment process we may share your personal data with the following recipients:
8.1.1 Cloud based service providers currently Workable, Jibe and OTYS;
8.1.2 Medical insurance provider;
8.1.3 Cloud based email partner currently Google;
8.1.4 Legal and regulatory authorities, on request, or for the purposes of reporting any actual or suspected breach of law or regulation;
8.1.5 Any relevant party, law enforcement agency, tribunal or court, to the extent necessary for the establishment, exercise or defence of legal rights;
8.1.6 Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties; and
8.1.7 Any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation).
8.2 In addition, we may disclose the personal data you provide to us to our group companies and affiliates or third party data processors who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this notice.
9 TRANSFERS OF PERSONAL DATA OVERSEAS
9.1 We may transfer the personal data we collect about you to other countries outside the EU. In most cases those countries will have been confirmed by the European Commission to provide an adequate level of protection for your personal data or in the case of the United States be subject to the Privacy Shield Framework.
9.2 Where this is not the case, we will only send your personal data to countries where other appropriate measures have been put in place to ensure that your personal data is treated in a way that is consistent with and which respects the EU and UK laws on data protection, such as using Standard Contractual Clauses already approved by the European Commission or by requesting your explicit consent. You can request further information by contacting us as specified in section 1.6.
10 RETENTION OF PERSONAL DATA
10.1 If your application is unsuccessful, we will retain your data for 4 weeks after the end of the application process unless you give us your consent to retain your data for longer (up to 12 months) so that we can notify you of future jobs.
10.2 If your application is successful the information which is gathered during the application process will be retained by us as part of your employee file for the duration of your employment and then for as long as the relevant limitation period or as required by the law in the country you are employed.
10.3 We retain your personal information for the periods set out so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.
10.4 Where we no longer need to process your personal data for the purposes set out in this notice then we will delete your personal data from our systems or anonymise it.
11 AUTOMATED DECISION MAKING
11.1 Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
11.1.1 Where we have notified you of the decision and given you 21 days to request a reconsideration;
11.1.2 Where it is necessary to perform a contract with you and appropriate measures are in place to safeguard your rights;
11.1.3 In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
11.2 If we make an automated decision on the basis of any particularly sensitive personal data, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
11.3 You will not be subject to any decisions about you using automated means unless we explicitly tell you otherwise.
12 YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
12.1 You have a number of rights in connection with the processing of your personal data, subject to certain conditions set out in the GDPR and in local law, including the right to:
12.1.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
12.1.2 Request the correction of the personal data that we hold about you. This enables you to have incomplete or inaccurate data we hold about you corrected;
12.1.3 Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no further legitimate reason for us continuing to process it;
12.1.4 Ask us to stop processing personal data where we are relying on a legitimate interest and where we do not have compelling reasons to override your rights and there is something about your particular situation which makes you want to object to processing on this ground;
12.1.5 Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
12.1.6 Request the transfer of personal data that you have provided to us to another party;
12.1.7 Lodge a complaint regarding the processing of your data with the Information Commissioner’s Office. Please see https://ico.org.uk/concerns/ for how to do this.
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