Privacy Notice
Privacy Notice for Applicants
(Permanent, Fixed Term Contract, Temporary and Voluntary positions)
Contents
- Introduction
- Document purpose
- Definition
- Data controller and processors
- The categories of personal data we hold
- Why we use this data
- Our lawful basis for using this data
- Collecting this information
- How we store this data
- Data sharing
- Data usage
- Cookies
- Job alerts
- Curriculum vitae (CV)
- Transferring data internationally
- Other websites
- Your rights - how to access personal information we hold about you
- Equal Opportunities
- Complaints
- Contact details
1. Introduction
1.1 Under data protection law, individuals have a right to be informed about how the Federation and its academies use any personal data that is held about them. We, the Harris Federation, comply with this right by providing Privacy Notices to individuals where we are processing their personal data.
1.2 We take great care in ensuring a safe and secure application and recruitment experience. The information you submit to us via our website, Applicant Tracking System, social media channels, or third-party job platforms, is for the sole purpose of employment opportunities with the Harris Federation and will is only used for the purposes set out in this policy.
2. Document purpose
2.1 The purpose of this Privacy Notice is to explain how the Federation collects, stores and uses personal data about individuals who are applying to work at our academies and in our Head Office.
3. Definition
3.1 An applicant is deemed to be an individual seeking employment who may register interest in employment opportunities, or complete an electronic form(s) as part of the recruitment process. Applicants are required to complete mandatory requests for information as part of this process, and will remain an applicant until the contractual commencement of employment.
4. Data controller and processors
4.1 Harris Federation is the Data Controller for the purposes of data protection law and therefore will determine the purposes for which personal data is processed (the ‘why’ and the ‘how’). Our academies and authorised 3rd parties, such as Cornerstone, process and ‘use’ data on behalf of (under the supervision/control) the Federation and are therefore Data Processors. Our postal address is:
Harris Federation
4th Floor Norfolk House
Wellesley Road, Croydon
CR0 1LH
4.2 The Federation will ensure that your personal data is processed fairly and lawfully, is accurate, is kept secure and is retained for no longer than is necessary.
5. The categories of personal data we hold
5.1 We process data relating to those we employ, or otherwise engage, to work at our academies and Head Office. The nature of the personal data we collect, depends on the position you are applying for and the stage of the recruitment process you reach.
Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not limited to:
- Personal information, including name, contact details, date of birth, email address and other personally identifiable data which is required in order to process your job application.
- Characteristics, such as race, ethnicity, nationality and sexual orientation.
- Financial information, such as your National Insurance number.
- Recruitment information, including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process.
- Qualifications and employment records, including work history, job titles, working hours, training records and professional memberships.
- Health, including any medical conditions and sickness records.
- Online information, that is in the public domain and where you can be identified using your current legal name, any previous names, or any other names that you may be, or have been known as, such as abbreviated or preferred first names.
- Other, including a copy of your national identity card or driving licence, passport type photograph.
6. Why we use this data
6.1 The purpose of processing this data is to help the Federation and its academies recruit the right person for the role we have advertised. The personal information is used for various reasons, including:
- to match your details with job vacancies and assist us in finding a position that is most suitable for you.
- facilitate safer recruitment, as part of our safeguarding obligations towards students; including online checks to review an individual’s public online presence to identify any content which would call into question their suitability to work with children1.
- facilitate right to work checks.
- inform our recruitment and retention policies.
- enable ethnicity and disability monitoring.
- fulfil contractual obligations with any third parties.
- to answer any enquiries you may have during the recruitment process.
- for evaluation, assessment and background screening as part of the onboarding process and pre-employment checks.
- to inform you of direct-market jobs and employment services, and advise you of news and Federation updates, events, reports and other information. Where we do so, you will be able to unsubscribe from such communications.
7. Our lawful basis for using this data
7.1 We only collect and use personal information about you when the law allows us to. Most commonly, we use it where we need to:
- Fulfil a contract we have entered into with you.
- Comply with a legal obligation in the field of employment, social security and social protection law.
- Online information will only be referenced during due diligence pre-employment checks conducted as part of an offer of employment. This is in line with the recommendation contained within Keeping Children Safe in Education 2022.
7.2 We may also use personal information about you where:
- You have given us consent to use it in a certain way e.g. pre-employment screening, safeguarding checks, reference requests, remarketing.
7.3 Where you have provided us with consent to use your data, you may withdraw this consent at any time. We will make this clear when requesting your consent, and explain how you go about withdrawing consent if you wish to do so.
7.4 Some of the reasons listed above for collecting and using personal information about you overlap, and there may be several grounds which justify the Federation’s use of your data.
8. Collecting this information
8.1 The personal information we collect about you comes primarily from applications or other forms and materials you submit to the Harris Federation during the course of your relationship with us.
8.2 Whilst the majority of information we collect from you is mandatory, there is some information that you can choose whether or not to provide to us. Whenever we seek to collect information from you, we will make it clear whether you must provide this information (and if so, what the possible consequences are of not complying), or whether you have a choice. However, failure to provide some of the requested information may result in our being unable to carry out our recruitment and pre-employment checks correctly and as efficiently as we would like.
8.3 We will try to ensure that all information we hold about you is accurate, complete and up to date, but we expect you to help us in this regard by promptly notifying us if there are any changes to your personal information.
9. How we store this data
9.1 Applicant data is stored via a third-party Data Processor, who facilitates the recording and storing of data collected during the application process. The Harris Federation remains the Data Controller at all times. Our Data Processor is registered with the Information Commissioner’s Office as a data processor with registration number Z1464102. As a hosted solution handling personal data, it complies with the UK and EU data protection laws. All data is stored on datacentres in the UK only.
9.2 Personal data will not be retained by the Federation for longer than is necessary in relation to the purpose for which it was collected. Once your application has ended, we will retain your personal application data in accordance with our Records Retention Policy.
10. Data sharing
10.1 We will not share personal information about you with any third party without your consent unless the law and our policies allow us to do so.
10.2 We may share personal information about you with trusted external service providers (third parties) for the purpose of:
- Providing services such as references, qualification checks, criminal reference checking services (Enhanced DBS as required), verification of the details you have provided from third party sources, psychometric evaluations or skills tests.
- Performing functions on our behalf such as professional advice, testing and development work on our technology systems and website, e-mail marketing, CV Database searching and social media networking.
10.3 All our third-party service providers are carefully selected, meet high data protection and security standards and are bound by contract to keep any information we share with them confidential. We only share the personal data with them that is necessary for the services they provide and they will only process that data in accordance with our instructions.
10.4 We will never rent or sell your data to any third party for their own marketing purposes and we will only disclose your data to another third party without your express consent when we are legally required to do so.
10.5 As part of the recruitment process we may share your personal information (including sensitive personal information) with one or more of our Academies in order to identify suitable jobs. This might also include a school, which is in the process of joining the Harris Federation. In such cases we only share information with selected persons of said school or academy, and their advisors e.g. governing body.
10.6 We may also release personal information to regulatory or law enforcement agencies, if they require us to do so.
11. Data usage
11.1 When you visit our careers website we may automatically collect information including:
- Information about your visit, including which areas users access most frequently and which services users access the most. We only use such data in the aggregate form. This information helps us determine what is most beneficial for our users and how we can continually improve our online services to create a better overall experience for our users.
- Website recording service information, including mouse clicks, mouse movements, page scrolling and any text keyed into website forms. Data collected by this service is used to improve our website usability.
11.2 Audience Matching to help us identify jobs, news, events etc which may be of interest to you. The information collected is stored and is used for aggregated and statistical reporting, and is not shared with anybody else.
11.3 Any information collected during the website records will be erased after 6 months, and any personally identifiable data entered will be marked and blanked out. This information cannot be used to identify you as an individual and none of the aggregate information collected will be shared outside of the Harris Federation.
11.4 If you receive emails from us we may use certain analytics tools to capture data such as when you open our email or click on any links or banners our email contains. This data helps us to gauge the effectiveness of our communications and marketing campaigns.
12. Cookies
12.1 Cookies are small text files that are placed on your device to help our website provide a better user experience. Cookies are stored on your individual device and you have full control over their use. You may deactivate or restrict the transmission of cookies by changing the settings of your web browser. Cookies that are already stored may be deleted at any time. To find out more about cookies and how to manage or delete them, visit www.aboutcookies.org.uk.
12.2 If you choose to disable cookies, you may not be able to use all the features on our website. For more information please see our Cookie policy.
13. Job alerts
13.1 Harris Federation has a job alerts service, which we use to notify you of job opportunities. To subscribe (consent to receive) job alerts emails, you will be required to provide your email address. This will be used for the purpose of keeping you informed, by email, of the latest jobs in your nominated regions, subjects, preferences and/or will provide you with news relating to the Harris Federation only.
13.2 Should you decide that you no longer wish to receive this information, unsubscribe links are provided in every job alert email that you receive. Job alerts emails originate from and are sent by Cornerstone On Demand.
14. Curriculum vitae (CV)
14.1 As part the application process to a job, you will have the option of submitting your CV via our website or by providing your CV to one of our resourcing team. CVs will only be considered as a supporting document in an application for a specific job, or for consideration by our resourcing team for positions that are yet to arise. Your CV will be stored in our application system and will be accessible only by the Harris Federation resourcing team in the UK, or selected individuals within our academies across the Federation.
14.2 You can update your CV at any time, simply by following the same procedure to submit a new application. Your old CV will automatically be archived providing the submission details remain the same (for example you submit both CVs using the same email address or you advise the relevant contact of your new submission). CVs will be deleted in accordance with our Records Retention Policy.
15. Transferring data internationally
15.1 Where you are registered as a candidate on our database in the UK, your personal information will not be accessible by, transferred or duplicated to anyone outside of the Harris Federation without your consent. Where your data may be transferred to any third party outside the European Economic Area (EEA) we will give you the opportunity to withhold your consent to such a transfer.
15.2 If we do transfer your personal data to a third party outside the EEA, we will only do so if they have been deemed to provide an adequate level of protection for personal data by the European Commission.
16. Other websites
16.1 Please note that clicking on links and banner advertisements may result in your transferral to another website - where data privacy practices may be different to that of the Harris Federation. Visitors should consult the other websites' privacy policies as we are not responsible for, and have no control over, information that is submitted to or collected by these third parties.
17. Your rights - how to access personal information we hold about you
17.1 Under data protection laws, individuals have a right to ask the Federation for a copy of the information we hold about you. As part of this process we may ask you to verify your identity and ask for more specific information about your request. Where we are legally permitted to do so, we may refuse your request and will give you reasons for doing so.
17.2 Individuals also have other rights regarding how their personal data is used and kept safe. These include having the right to:
- Object to the use of your personal data if it would cause, or is causing, damage or distress.
- Prevent your data being used to send direct marketing.
- Object to the use of your personal data for decisions being taken by automated means (by a computer or machine, rather than by a person).
- In certain circumstances, have inaccurate personal data corrected, deleted or destroyed, or restrict processing.
17.3 To exercise any of these rights, please contact the Harris Federation Data Protection Officer (DPO).
Contact details can be found in section 20.
18. Equal Opportunities
18.1 The Harris Federation is an equal opportunities employer and a company committed to diversity. This means that all job applicants and members of staff will receive equal treatment and that we will not discriminate on grounds of gender, marital status, race, ethnic origin, colour, nationality, national origin, disability, sexual orientation, religion or age.
18.2 As part of our commitment to equal opportunities we may from time to time use information provided by you for the purposes of diversity monitoring. All such information will be used on an anonymised basis.
19. Complaints
19.1 We take any complaints about our collection and use of personal information very seriously. If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with the DPO in the first instance.
19.2 Alternatively, you can make a complaint to the Information Commissioner’s Office:
- Report a concern online at https://ico.org.uk/concerns
- Call 0303 123 1113.
- Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
20. Contact details
20.1 If you have any questions, concerns or would like more information about anything mentioned in this Privacy Notice please contact our DPO, details below:
Data Protection Officer, Harris Federation