HRG Registration Privacy Policy

Data controller: Herts Resourcing Group (HRG), London Road, Ware, Herts, SG12 9JF

Data protection officer: Olive Oliver – Associate Director ooliver@hrc.ac.uk

HRG collects and processes personal data relating to its registered candidates to manage its relationship with them. HRG is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does HRG collect?

HRG collects and processes a range of information about you. This includes:

your name, address and contact details, including email address and telephone number, date of birth and gender;
the terms and conditions of your engagement;
details of your qualifications, skills, experience and career history, including start and end dates, with previous employers and with HRG;
information about your remuneration, including benefit entitlements;
details of your bank account and national insurance number;
information about your marital status, next of kin, dependants and emergency contacts;
information about your nationality and entitlement to work in the UK;
information about your criminal record, including allegations of criminal offences;
details of your schedule (days of work, working hours and details of any days that you are not generally available for work) and attendance at work;
details of periods of leave (such as holiday) taken by you, and the reasons for the leave;
information about medical or health conditions, including whether you have a disability for which HRG needs to make reasonable adjustments; and
equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.

HRG 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.

HRG will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. HRG will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Data will be stored in a range of different places, including on your application record, in HRG’s HR Management Systems and on other IT systems (including HRG’s email system).

Why does HRG process personal data?

HRG needs to process data to take steps at your request prior to entering into an engagement with you. It also needs to process your data to enter into an engagement with you.

In some cases, HRG needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a worker’s right to work in the UK in accordance with government guidance, deduct tax, comply with health and safety laws, ensure that workers are receiving the national minimum wage, to auto-enrol workers in pension schemes and to enable workers to take the holiday and breaks to which they are entitled. For certain positions, it is necessary to carry out criminal records checks to ensure that individuals are permitted to undertake the role in question.

In other cases, HRG has a legitimate interest in processing personal data before, during and after the end of the relationship. Processing candidate data allows HRG to:

manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.
maintain accurate and up-to-date records and contact details (including details of who to contact in the event of an emergency), and records of workers’ contractual and statutory rights;
ensure acceptable conduct within the workplace;
keep a record of absence to allow effective workforce management and ensure that workers are receiving the pay to which they are entitled;
obtain occupational health advice, to ensure that HRG complies with duties in relation to individuals with disabilities, meets its obligations under health and safety law, and ensures that workers are receiving the pay or other benefits to which they are entitled;
operate and keep a record of working hours and holidays to allow effective workforce management, to ensure that HRG complies with duties in relation to leave entitlement, and to ensure that workers are receiving the pay or other benefits to which they are entitled;
ensure effective general HR and business administration; and
respond to and defend against legal claims.

Where HRG relies on legitimate interests as a reason for processing data, it has considered whether those interests are overridden by the rights and freedoms of registered candidates and has concluded that they are not.

HRG 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.

Where HRG processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes as permitted by the Data Protection Act 2018/reasons of substantial public interest.

For some roles, HRG is obliged to seek/seeks information about criminal convictions and offences. Where HRG 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/it to comply with a regulatory requirement to establish whether an individual has committed an unlawful act or been involved in dishonesty or other improper conduct/the purposes of preventing or detecting unlawful acts.

If your application is unsuccessful, HRG will keep your personal data on file in case there are future employment opportunities for which you may be suited. HRG will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time by contacting Steve Underwood.

Who has access to data?

Your information will be shared with HRG Clients for the purposes of the recruitment exercise. This includes members of the client’s HR and recruitment team, interviewers involved in the recruitment process, managers in the client’s business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

Your information will be shared internally, including with members of the HR and recruitment team (including payroll) and IT staff if access to the data is necessary for the performance of their roles.

HRG can, where relevant, share your data with third parties in order to obtain background checks from third-party providers and obtain necessary criminal records checks from the Disclosure and Barring Service or report suspected offences to the appropriate authorities. HRG can also share your data with former employers to obtain references for you. HRG may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances, the data will be subject to confidentiality arrangements.

HRG also shares your data with third parties that process data on its behalf, in connection with payroll, the provision of pension benefits and the provision of occupational health services.

HRG will not transfer your data to countries outside the UK.

How does HRG protect data?

HRG takes appropriate measures to ensure the security of your personal information, including implementing technical and organisational measures to prevent unauthorised access, use, or disclosure.

Where HRG engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

For how long does HRG keep data?

HRG will hold your personal data for the duration of any worker engagement and will hold your data on file for one year after the end of the relevant recruitment process. If you agree to allow HRG to keep your personal data on file, HRG will hold your data on file for a further year for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data is deleted or destroyed.

Your rights

As a data subject, you have a number of rights. You can:

access and obtain a copy of your data on request;
require HRG to change incorrect or incomplete data;
require HRG to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
object to the processing of your data where HRG is relying on its legitimate interests as the legal ground for processing; and
ask HRG to stop processing data for a period if data is inaccurate or there is a dispute about whether your interests override HRG’s legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact Steve Underwood – sunderwood@hrg.uk.com You can make a subject access request by completing HRG’s form for making a subject access request. Subject access request V2.docx

If you believe that HRG has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to HRG during the recruitment process. However, if you do not provide the information, HRG may not be able to process your application properly or at all.

You have some obligations under any worker engagement to provide HRG with data. In particular, you are required to report absences from work. You may also have to provide HRG with data in order to exercise your statutory rights, such as in relation to holiday entitlements. Failure to provide the data may mean that you are unable to exercise your statutory rights.

Certain information, such as contact details, your right to work in the UK and payment details, have to be provided to enable HRG to enter a worker engagement with you. If you do not provide other information, this will hinder HRG’s ability to administer the rights and obligations arising as a result of worker engagement efficiently.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.