
Recruitment Privacy Notice
This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the application process.This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the application process. It applies to all individuals enquiring about or applying for a position at the School, including positions as a member of staff (full time or part time), contractors, workers, directors, volunteers and peripatetic staff. It also applies to individuals we will contact in order to find out more about our job applicants, including referees, or those that are provided by job applicants as an emergency contact.
If you are enquiring about a position at the School, or applying to work with us (whether as an employee, worker, or contractor), please ensure you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
Herne Hill School (the “School”) is a ‘controller’ in relation to personal data it gathers, uses and holds. The School’s registered address is The Old Vicarage, 127 Herne Hill, London SE24 9LY, and its contact details are (phone) 020 7274 6336 and (email) [email protected]
We will comply with the data protection law and principles when collecting, using and holding (or “processing”) your personal information. This means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in a way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept safely and securely.
How we collect your information
Before you are employed or engaged by the School, we may collect your personal data in a number of ways, for example:
- from the information you provide to us before making a job application;
- when you submit a formal application to work for us, and provide your personal data in application forms and covering letters, or when you complete a self-declaration, etc.;
- when you attend an interview; and
- from third parties, for example the Disclosure and Barring Service (“DBS”) and referees (including your previous or current employers or school), or from third party websites (as part of online suitability checks for shortlisted candidates) or (if you are a contractor or a substitute) your own employer or agent, in order to verify details about you and/or your application to work for us.
The types of information we collect
We may collect the following types of personal data about you:
- contact and communications information such as your address; contact details; records of communications and interactions we have had with you; etc.
- biographical, educational and social information such as your name(s); nationality; date of birth; images captured by the school’s CCTV system or for signing-in purposes when visiting; details of your education and references from your institutions of study; your interests and extra-curricular activities, etc.
- work related information such as details of your work history and references from your current and/or previous employer(s); details of your professional activities and interests; your involvement with and membership of sector bodies and professional associations; details of your right to enter, live and work in the UK, including immigration status information (i.e. about your entitlement to work in the UK), including copies of passport information (if applicable); etc.;
- and any other information relevant to your employment or other engagement to work for the school.
Where this is necessary for your employment or other engagement to work for us, we may also collect special categories of data, and information about criminal convictions and offences, including:
- information revealing your racial or ethnic origin;
- trade union membership, where applicable;
- information concerning your health and medical conditions (for example, where required to monitor and record sickness absences, dietary needs, or to make reasonable adjustments to your working conditions or environment);
- information about certain criminal convictions (for example, where this is necessary for due diligence purposes, whether by self-declaration or otherwise, or for compliance with our legal and regulatory obligations).
However, this will only be undertaken where and to the extent it is necessary for a lawful purpose in connection with your potential employment or other engagement to work for the school.
The bases for processing your personal data, how that data is used and whom it is shared with
We process your personal data because this is necessary for:
- carrying out a fair and diligent recruitment process, including progressing applications in line with equality of opportunity treatment, arranging interviews, informing you of the outcome at various stages, making informed decisions about progressing candidates, carrying out required and appropriate due diligence and checks, maintaining required records, etc.;
- potentially entering into, and then fulfilling, a contract with you, such as a contract of employment or other engagement with us;
- fulfilling our (or sometimes a third party’s) “legitimate interests”, including our interests in running the School in a professional, sustainable manner, in accordance with all relevant ethical, educational, legal and regulatory duties and requirements (whether or not connected directly to data protection law);
- compliance with our “legal obligations”, for example in connection with statutory requirements and guidance related to recruitment, employment, education, child welfare such as the statutory guidance contained in Keeping Chidren Safe in Education (KCSIE), health & safety, etc.
For the purposes referred to in this Privacy Notice and relying on the grounds for processing as set out above, we may share your personal data with certain third parties. We may disclose limited personal data (including in limited cases special category or criminal data) to a variety of recipients including:
- other employees, agents and contractors;
- DBS and other government authorities and/or appropriate regulatory bodies;
- third party background check agencies;
- external auditors or inspectors;
- our advisers where it is necessary for us to obtain their advice or assistance, including insurers, lawyers, accountants, or other external consultants;
when the school is legally required to do so (by a court order, government body, law enforcement agency or other authority of competent jurisdiction), for example HM Revenue and Customs or police.
Information may be held on the School’s premises in our filing systems and on our servers. It may also be held on our behalf by third party agencies, service providers and representatives for outsourced functions such as IT, cloud storage, MIS and other records management, website support, graphic design or catering.
We keep the personal information (including interview notes) that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed or considered to be reasonable, after which it will be destroyed.
How long we keep your information will depend on whether your application, or the application you are supporting (e.g. as a referee) is successful and you (the job applicant) become employed by us, the nature of the information concerned and the purposes for which it is processed. This is likely to be for twelve months from the communication of the outcome of the recruitment exercise. If there is a lawful reason for keeping recruitment records for longer, we may do so, considering if appropriate whether the records can be pseudonymised, and the longer period for which they will be kept.
If you are an applicant and your application is successful and you join the School, and once the twelve month period set out above comes to an end, we will keep the recruitment information that is necessary in relation to your employment. Further information will be available upon becoming a staff member, in the Staff Privacy Notice contained in the Employee Handbook.
If you are an applicant and your application is unsuccessful, and you would like us to retain your personal information on file, on the basis that a further opportunity may arise in future for which you may wish to be considered, please contact us to give your explicit consent to the School retaining your personal information for a fixed period on that basis.
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes personal information being locked away, password protected or encrypted. We limit access to your personal information to those who have a genuine 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 personal data breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
The School has appointed its Bursar as Privacy Officer to deal with your requests and enquiries concerning the School’s processing of your personal data (see section on “Your Rights” below) and endeavour to ensure that all personal data is processed in compliance with this policy and data protection law.You can contact the School’s Privacy Officer at the School address, using the [email protected] email address or by phone 020 7274 6336, extension 1010.
You have the following rights:
- to obtain access to, and copies of, the personal data that we hold about you;
- to require us to correct the personal data we hold about you if it is incorrect;
- to require us (in certain circumstances) to erase your personal data;
- to request that we restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
- to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. The School will endeavour to respond to any such requests as soon as is reasonably practicable and in any event within statutory time-limits (which is generally one month, but actually fulfilling more complex or multiple requests, e.g. those involving third party information, may take 1-2 months longer).
Any comments or queries about this Privacy Notice should be directed to the School’s Privacy Officer.
If you believe that the School has not complied with this Privacy Notice or acted otherwise than in accordance with data protection law, please contact the School’s Privacy Officer or utilise the School’s complaints procedure, in which case you should also notify the School’s Privacy Officer.
You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (“ICO”), although the ICO recommends that steps are taken to resolve the matter with the School before involving the regulator.
