Recruitment Privacy Policy Your personal information and what we do with it

Recruitment Privacy Policy

Your personal information and what we do with it

Recruitment Privacy Policy

This Privacy Policy is specific to applicants seeking employment with Market Harborough Building Society.

Profiling means any form of automated processing of your personal information to evaluate certain personal aspects about you, such as to analyse or predict aspects concerning your economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Process or processing includes everything we do with your personal information from its collection, right through to its destruction or deletion when we no longer need it.  This includes for instance collecting it (from you), obtaining it (from other organisations), using, sharing, storing, retaining, deleting, destroying or transferring it overseas.

Legitimate interests is mentioned in our privacy notice because data protection laws allow the processing of personal information where the purpose is legitimate and is not outweighed by your interests, fundamental rights and freedoms.  Those laws call this the legitimate interests legal ground for personal data processing.

Market Harborough Building Society of Welland House, 15-17 The Square, Market Harborough, Leicestershire, LE16 7PD is a data controller of your personal information.  This means information that is about you or from which we can identify you.  This privacy notice describes how we deal with your personal information.  We are the data controller of this information under relevant data protection laws because in the context of our business relationship with you we decide how and why it is processed in the ways explained in this privacy notice.  When we use terms such as we, us and our in this notice, we mean Market Harborough Building Society.

Our Data Protection Officer, Julie Mottram, can be contacted at dpo@mhbs.co.uk or by calling 01858 412250 if you have queries about this privacy notice or wish to exercise any of the rights mentioned in it.

You will see at the end of this privacy notice that we mention the privacy notices of Fraud Prevention Agencies and Credit Reference Agencies (CRAs).  We do need to share these with you.  Please read them carefully and contact those organisations if you have questions (their details are in their notices).

This privacy notice may be updated from time to time.  We will advise you of the changes and provide an up to date version.

The personal and sensitive classes of information we process may include:

  • your name, address and contact details, including email address and telephone number;
  • details of your qualifications, skills, experience, education and employment history;
  • information about your current level of remuneration, including benefit entitlements;
  • whether or not you have a disability for which the Society needs to make reasonable adjustments during the recruitment process;
  • information about your entitlement to work in the UK and;
  • equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

Except where legislation allows it, this information cannot be processed or passed to a third party without your explicit consent.

The Society collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

We will generally collect your personal information from you directly. If you are introduced to us by an intermediary such as employment agency, we will obtain some personal information about you indirectly from them when they introduce you to us.

In addition, we obtain your personal information from other sources such as Credit Reference Agencies, your previous employer, HMRC, DWP, other organisations to assist in prevention and detection of crime, police and law enforcement agencies.

Some of the personal information obtained from Credit Reference Agencies will have originated from publicly accessible sources.  In particular, Credit Reference Agencies draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll).  We explain more about Credit Reference Agencies below.  We have also mentioned above in the lists of personal information that we process some of the CRAs’ other sources of information (which are our own source of information too).

Data protection laws require us to explain what legal grounds justify our processing of your personal information (this includes sharing it with other organisations).  For some processing more than one legal ground may be relevant (except where we rely on a consent). Here are the legal grounds that are relevant to us:

1. Processing necessary to perform our contract with you:

a) the Society needs to process data to take steps at your request prior to entering into a contract with you; and

b) it also needs to process your data to enter into a contract with you.

2. Where we consider that, on balance, it is appropriate for us do so, processing necessary for the following legitimate interests which apply to us and in some cases other organisations (who we list below) are:

a) during the recruitment process to assess and confirm a candidate’s suitability for employment and decide to whom to offer a job;

b) to test the performance of our internal processes;

c) to adhere to guidance and best practice under the regimes of governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman and the Information Commissioner’s Office;

d) for management and audit of our business operations including accounting;

e) to carry out searches at Credit Reference Agencies pre-application, at the application stage, and periodically after that. Where you have been introduced to us by an intermediary they may do these searches on our behalf;

f) to carry out monitoring and to keep records (see below);

g) to administer our good governance requirements such as internal reporting and compliance obligations or administration required for AGM processes by implementing technical and organisational measures including internal data protection policies, employee training, internal audits of processing activities and appointing a Data Protection Officer;

h) to process data from job applicants to respond to and defend against legal claims;

i) for market research and analysis and developing statistics; and

j) when we share your personal information with these other people or organisations;

          • claimants, beneficiaries, assignees and payees and any person with power of attorney over your affairs (in each case only if relevant to you);
          • family, associates or representatives of the person whose personal data we are processing;
          • current, past or prospective employers;
          • trade and business associates and professional advisers;
          • other payment services providers such as when you ask us to share information about your account with them;
          • the intermediary who introduced you to us;
          • our legal and other professional advisers, auditors and actuaries;
          • financial institutions and trade associations;
          • governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman and the Information Commissioner’s Office;
          • tax authorities who are overseas for instance if you are subject to tax in another jurisdiction we may share your personal information directly with relevant tax authorities overseas (instead of via HMRC);
          • other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions;
          • buyers and their professional representatives as part of any restructuring or sale of our business or assets;
          • Credit Reference Agencies (see below where we explain more and refer to a link to more information); and
          • healthcare, social and welfare organisations

Where the Society relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of job applicants, employees or workers and has concluded that they are not.

3. In some cases, the Society needs to process data to ensure that it is complying with its legal obligations. For example, the Society processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment. It is also required to check a successful applicant’s eligibility to work in the UK before employment starts.  Other legal obligations:

a) processing of your special categories of personal data such as about your health;

b) processing that we need to do to fulfil our legal obligations and regulatory requirements;

c) when we share your personal information with other people and organisations such as your relatives, social services, your carer, the person who has power of attorney or court of protection over your affairs;

d) for compliance with laws that apply to us;

e) for establishment, defence and enforcement of our legal rights;

f) for activities relating to the prevention, detection and investigation of crime;

g) to carry out identity checks, anti-money laundering checks, and checks with the Disclosure Barring Service;

h) to deal with requests from you to exercise your rights under data protection laws;

i) to process information about a crime or offence and proceedings related to that (in practice this will be relevant if we know or suspect fraud); and

j) when we share your personal information with these other people or organisations:

          • claimants, beneficiaries, assignees and payees and any person with power of attorney over your affairs (in each case only if relevant to you);
          • family, associates or representatives of the person whose personal data we are processing;
          • current, past or prospective employers;
          • trade and business associates and professional advisers;
          • other payment services providers such as when you ask us to share information about your account with them;
          • the intermediary who introduced you to us;
          • our legal and other professional advisers, auditors and actuaries;
          • financial institutions and trade associations;
          • governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman, the Information Commissioner’s Office and under the Financial Services Compensation Scheme;
          • tax authorities who are overseas for instance if you are subject to tax in another jurisdiction we may share your personal information directly with relevant tax authorities overseas (instead of via HMRC);
          • other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions;
          • buyers and their professional representatives as part of any restructuring or sale of our business or assets;
          • Credit Reference Agencies (see below where we explain more and refer to a link to more information); and
          • healthcare, social and welfare organisations.

Where the Society processes other special categories of data, such as information about ethnic origin, sexual orientation, health, religion or belief, age, gender or marital status, this is done for the purposes of equal opportunities monitoring with the explicit consent of job applicants, which can be withdrawn at any time.

For some roles, the Society is obliged to seek information about criminal convictions and offences. Where the Society 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/comply with a regulatory requirement to establish whether or not an individual has committed an unlawful act or been involved in dishonesty or other improper conduct.

4) Processing with your consent:

a) when you request that we share your personal information with someone else and consent to that; and

b) for some of our processing of special categories of personal data such as about your health.

We will tell you if we want to use your data for purposes other than those under which they were collected, prior to undertaking such processing.

Much of what we do with your personal information is not based on your consent, instead it is based on other legal grounds. For processing that is based on your consent, you have the right to take back that consent for future processing at any time. You can do this by contacting us. The consequence might be that we cannot take into account special categories of personal data such as about your health.

We will tell the intermediary who introduced you to us that you have withdrawn your consent only if it is our data processor (this means an organisation who is processing personal information on our behalf) or if we are required to do so when you exercise certain rights under data protection laws. You should make sure to contact them directly to withdraw your consent for what they do with your personal information as a data controller in their own right.

Your information may be transferred to and stored in locations outside the European Economic Area (EEA), including countries that may not have the same level of protection for personal information.

When we do this, we’ll ensure it has an appropriate level of protection and that the transfer is lawful. We may need to transfer your information in this way to carry out our contract with you, to fulfil a legal obligation and/or for our legitimate interests. In some countries the law might compel us to share certain information, e.g. with tax authorities. Even in these cases, we’ll only share your information with people who have the right to see it.

For more information about suitable safeguards and (as relevant) how to obtain a copy of them or to find out where they have been made available you can contact our Data Protection Officer using the details at the start of the document.

In order to process your application, we will perform credit and identity checks on you with one or more CRAs. Background checking will include electoral roll, adverse credit i.e. CCJs, bankruptcy and directorships.

We will use this information to:

• verify the accuracy of the data you have provided to us; and
• prevent criminal activity, fraud and money laundering.

We will continue to exchange information about you with CRAs while you have a relationship with us. When CRAs receive a search from us they may place a search footprint on your credit file that may be seen by other lenders.

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at the Uniform Resource Locator (URL) link which we refer to later on in this privacy notice.

This is explained at the URL link which we refer to later on in this privacy notice.

You should tell us without delay so that we can update our records. The contact details for this purpose are: Human Resources and Premises Manager, Market Harborough Building Society, Welland House, 15-17 The Square, Market Harborough, Leicestershire, LE16 7PD, telephone 01858 412250.

You are under no statutory or contractual obligation to provide data to the Society during the recruitment process. However, if you do not provide the information, the Society may not be able to process your application properly or at all. If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the UK and satisfactory references.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

In this section monitoring means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, in person face to face meetings and other communications.

We may monitor where permitted by law and we will do this where the law requires it. In particular, where we are required by the Financial Conduct Authority’s regulatory regime to record certain telephone lines or in person meetings (as relevant) we will do so.

Some of our monitoring may be to comply with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, to have a record of what we have discussed with you and actions agreed with you, to protect you and to provide security for you and for quality control and training purposes.

Some of our monitoring may check for obscene or profane content in communications.

Telephone calls and/or in person meetings between us and you in connection with your employment application may be recorded to make sure that we have a record of what has been discussed and what your instructions are. We may also record these types of calls for quality control and staff training purposes.

Unless we explain otherwise to you, we will hold your personal information for the following periods:

  • Retention in case of queries. We will retain the personal information that we need to keep in case of queries from you (for instance, if you apply unsuccessfully for a vacancy, product or service) for 12 months unless we have to keep it for a longer period (see directly below);
  • Retention in case of claims. We will retain the personal information that we need to keep for the period in which you might legally bring claims against us which in practice means 15 years unless we have to keep it for a longer period (see directly below); and
  • Retention in accordance with legal and regulatory requirements. We will retain the personal information that we need to keep even after the relevant contract you have with us has come to an end to satisfy our legal and regulatory requirements.

We may also be required to retain some of your personal information after your death so we have the information we need to pay benefits to your dependents and to answer queries relating to your benefits.

If you would like further information about our data retention practices, contact our Data Protection Officer.

Here is a list of the rights that all individuals have under data protection laws.  They do not apply in all circumstances.  If you wish to exercise any of them we will explain at that time if they are engaged or not.

  • The right to be informed about our processing of your personal information;
  • The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
  • The right to object to processing of your personal information
  • The right to restrict processing of your personal information;
  • The right to have your personal information erased (the “right to be forgotten”);
  • The right to request access to your personal information and to obtain information about how we process it;
  • The right to move, copy or transfer your personal information (“data portability”);
  • Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

If you would like to exercise any of these rights, please contact DPO@mhbs.co.uk or call 01858 412250.  You can make a subject access request by putting your request in writing.  The contact details for this purpose are: Human Resources and Premises Manager, Market Harborough Building Society, Welland House, 15-17 The Square, Market Harborough, Leicestershire, LE16 7PD.

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/ You can contact our Data Protection Officer or request the leaflet “Your Data Protection Rights” by emailing dpo@mhbs.co.uk, or calling us on 01858 412250 for more details on all the above.

If you wish to exercise any of these rights against the Credit Reference Agencies, the Fraud Prevention Agencies, or an intermediary who is data controller in its own right, you should contact them separately.

Your personal information may be converted into statistical or aggregated data which cannot be used to re-identify you.  It may then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this privacy notice.

Recruitment processes are not based on automated decision-making or profiling.

We have mentioned that we share your personal information with Fraud Prevention Agencies and Credit Reference Agencies. They require us to pass on to you information about how they will use your personal information to perform their services or functions as data controllers in their own right. These notices are separate to our own.

ID Verification and Fraud Prevention Checks

Credit Reference Agency Information Notice

Last updated: May 2019