Lifeplus Europe Limited May 2018
Lifeplus Europe Limited Privacy Policy for Recruitment
Purpose
This Notice describes, as required by the General Data Protection Regulation (“GDPR”), how Lifeplus collects and processes your personal information, during your recruitment journey with us.
This Notice defines the data protection principles contained within the GDPR, what personal information we collect and hold about you and why, who we may share your personal information with and why, and your rights in relation to this information.
Introduction
We are Lifeplus Europe Ltd (“Lifeplus”). Lifeplus Europe is a data controller and a data processor. Our nominated representative for data protection and the purposes of the General Data Protection Regulation (EU/2016/679) is Sam Arnold. Our registered office is Lifeplus House, Little End Road, Eaton Socon, St. Neots, Cambridgeshire, PE19 8JH, England. We may be reached at T +44 1480 224610; F +44 1480 224611; email to info.eu@lifeplus.com.
On occasion, other companies within the Lifeplus group may handle personal information as a controller or processor.
Lifeplus is committed to protecting the privacy and security of your personal information. As a data controller, Lifeplus is responsible for deciding how and why your personal information is collected and processed. Lifeplus is required under data protection laws to notify you of the information contained in this Notice.
It is important that you read this Notice, together with any other notice or policy, (including the Privacy Policy) which we may provide you with on specific occasions when your personal information is being collected or processed, so that you are fully aware of how your personal information is being used by Lifeplus.
Scope
This Notice applies to all potential employees, workers or contractors, who have provided personal information either directly or indirectly (i.e. through a recruitment agency) to Lifeplus.
Definitions
“Personal Information” – Information is personal if it relates to an individual (a data subject) and an individual can be identified from that information. Examples of personal information include names, addresses, email addresses, telephone numbers, images, National Insurance numbers, banking and credit card details.
“Special Category Information” – Examples of special category information include racial or ethnic origin, political opinions, religious or other beliefs, trade union membership, genetics, biometrics, health, sex life and sexual orientation. Lifeplus Europe Limited May 2018
Data Protection Principles
Lifeplus is dedicated to complying with data protection law. This states that any personal information held about you must be:
1. Used lawfully, fairly and in a transparent way
2. Collected only for valid purposes that have been clearly explained to you, and not used in any way that is incompatible with those purposes
3. Relevant to the purposes for which it was collected, and limited only to those purposes
4. Accurate and kept up to date
5. Kept only as long as is necessary for the purposes for which it was collected
6. Kept securely
Types of Personal Information Collected and Held
Lifeplus is permitted to collect, retain and process the following types of personal information about you:
Personal contact details such as your name, address, telephone numbers and personal email address
Date of birth
Gender
Nationality
Passport details, including a scan / photocopy for all potential employees
Right to work documentation
Location of current employment or workplace
Any other recruitment information provided by you, to us, in a curriculum vitae (CV) or cover letter or online application, or received from a third party (such as a recruitment agency) as part of your application to Lifeplus
Compensation information
Lifeplus may collect, retain and process the following types of special category information once an offer of employment, on any terms, is made:
Information about criminal convictions and offences
How Lifeplus Uses Personal Information
Lifeplus will only use your personal information, or special category information when there is a lawful basis for doing so. Most commonly, your information will be used in the following circumstances:
1. When needed to perform a contract entered into with you
2. When needed to comply with a legal obligation
3. When it is necessary for the legitimate interests of Lifeplus and your interests and rights under data protection law do not override those interests
Lifeplus Europe Limited May 2018
Lifeplus may also use your personal information, or special category information in the following situations, which are likely to be rare, and wouldn’t be considered part of the day to day processing activities of Lifeplus:
1. When needed to protect your interests (or some else’s interests)
2. Where it is needed in the public interest
The situations in which Lifeplus may process your personal information as part of the recruitment process are listed below:
To communicate with you, where necessary
Making a decision about your recruitment opportunity or appointment
Determining the terms on which you will work for Lifeplus
Checking that you are legally entitled to work in the UK
Ascertaining your fitness to work
Complying with health and safety obligations
To prevent fraud
Some of the above reasons for processing may overlap, and there may be several grounds which justify the use of your personal information, or special category information. For further details please email privacy@lifeplus.com.
Failure to Provide Personal Information
If you fail to provide certain information when requested Lifeplus may not be able to fulfil some or all of its obligations to you, and / or may be prevented from complying with legal requirements.
If you feel that you are being requested to provide more personal information than necessary please email privacy@lifeplus.com.
How Special Category Information is Used
Special category information is considered more sensitive than personal information, and as such requires a greater level of protection.
Lifeplus is required to have further justification for processing this type of information, and will only do so in the following circumstances:
1. In limited circumstances, with your explicit written consent
2. Where required to carry fulfil a legal obligation or exercise rights in connection with your employment
3. Where it is needed in the public interest
Change of Purpose
Lifeplus will only use your personal information for the purpose(s) for which it was collected. In the event that it is needed for an unrelated purpose, Lifeplus will notify you and explain the lawful basis for the processing. Lifeplus Europe Limited May 2018
Information Regarding Criminal Convictions
Lifeplus will only collect information about criminal convictions where legally permitted. Information regarding criminal convictions will either be requested from you directly during your recruitment or appointment, or will be obtained from a suitable background check provider.
Data Sharing
During the course of your application to Lifeplus your personal information will only be shared with other members of the Lifeplus group of companies (including those located outside of the EEA).
Your personal information will be shared where necessary, and in the following circumstances:
To make a decision about your recruitment or appointment
To determine the terms on which you will work for Lifeplus
Where Lifeplus has a legitimate interest in doing so
Where required by law
Data Security
Lifeplus have put in place the appropriate and necessary security measures to protect your personal information, or special category information, from being accidentally lost, altered, disclosed or used or accessed in an unauthorised way. In addition, Lifeplus limits access to this information to only those employees, agents, contractors and other third parties who have a business need to know.
Lifeplus has a number of policies in place to safeguard your personal information, and special category information, and to deal with suspected or actual breaches of this information. For further details please contact privacy@lifeplus.com.
Data Retention
Your personal information will be processed for the duration of your recruitment journey with Lifeplus, and will then be retained for a further twelve months, in which time Lifeplus may contact you about other employment opportunities.
If you would like your contact details removed at any time, or would like to restrict how your personal information is processed, please see below on “Your Rights”.
Your Rights
Under certain circumstances you have the legal right to:
Request access to your personal information
Request, where applicable, that personal information held about you by Lifeplus is corrected
Request erasure of your personal information
Lifeplus Europe Limited May 2018
Object to the processing of your personal information where Lifeplus is relying on a legitimate interest as the lawful basis for that processing
Request that the processing of your personal information is restricted
Request that the personal information held about you by Lifeplus is transferred to another party
If you would like to enforce any of the above rights please contact privacy@lifeplus.com.
Changes to this Privacy Policy
Lifeplus reserves the right to update this Privacy Policy at any time. This Privacy Policy was last updated in May2018.