Recruitment Privacy Notice

This privacy notice tells you what to expect us to do with your personal information. 

• Contact details 
• What information we collect, use, and why 
• Lawful bases and data protection rights 
• Where we get personal information from 
• How long we keep information 
• How to complain

Contact details

St James Medical Centre - 189A St James Road, Croydon, CR0 8BZ
Data Protection Officer: Laura.Watson@swlondon.nhs.uk

What information we collect, use, and why 

We collect or use the following personal information for recruitment purposes:

• Contact details (eg name, address, telephone number or personal email address)
• Date of birth
• National Insurance number
• Copies of passports or other photo ID
• Employment history (eg job application, employment references or secondary employment)
• Education history (eg qualifications)
• Right to work information
• Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)

We may collect or use the following special category information for recruitment purposes, where relevant or where you choose to provide it: 

• Racial or ethnic origin 
• Sexual orientation   
• Health information 
• Disability status  
• Religion or belief  

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. 
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. 
• Your right to erasure - You have the right to ask us to delete your personal information. 
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. 
• Your right to object to processing - You have the right to object to the processing of your personal data.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. 
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data 

Our lawful bases for collecting or using personal information for recruitment purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • We process personal information for our legitimate interests in recruiting suitable candidates, managing the recruitment process, assessing applicants’ skills, qualifications and suitability for a role, communicating with candidates, and maintaining accurate recruitment records. This processing is necessary to enable us to identify and appoint the most appropriate candidates and to operate an effective and fair recruitment process. We only collect information that is relevant and necessary for recruitment and do not use it for unrelated purposes. We recognise that applicants’ personal information is sensitive, so we take appropriate measures to protect it, restrict access to authorised staff only, and retain it only for as long as necessary in accordance with our retention policies. We have balanced our legitimate interests against the rights and freedoms of applicants and consider that our processing is fair, proportionate and within the reasonable expectations of individuals applying for employment. Applicants retain their rights under UK data protection law, including the right to object to processing based on legitimate interests where applicable.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Where we get personal information from

• Directly from you
• Previous employment (for employment references)
• Disclosure and Barring Service
• Professional registration bodies (such as the General Medical Council, Nursing and Midwifery Council or Health and Care Professions Council, where applicable)

How long we keep information

• Successful applicants: Recruitment information will become part of your employee record and will be retained in accordance with the NHS Records Management Code of Practice and the Practice's Records Management Policy.
• Unsuccessful applicants: Recruitment records will normally be retained for 6 months after the recruitment process has ended, unless a longer retention period is required by law or with your consent.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

How to contact the ICO