Bipsync UK Limited (“the Company”) is committed to protecting the privacy and security of your personal information. The Company is a “data controller”. This means that we are responsible for deciding how we gather, hold and use personal information about you and this privacy notice describes how we do that during and after your relationship with us for recruitment purposes.
This notice applies to all applicants, whether or not they are eventually employed or engaged by the Company. We may update this notice at any time and will provide you with a new privacy notice when we make substantial updates.
Data Protection Principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The Kind of Information We Hold About You
We may collect, store, and use the following categories of personal information about you up to and including the shortlisting stage of the recruitment process:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
- Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests;
- Date of birth;
- Details of your referees.
- Any additional information you provide to us in your curriculum vitae and covering letter or your application form.
- Any information you provide to us during an interview.
We may collect the following information at a later stage, usually after making a conditional offer of employment:
- Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers.
- Information regarding your academic and professional qualifications.
- Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information. This is to comply with our legal obligations, and enable us to carry out required statutory checks, such as verifying your right to work.
- Reports prepared by certified Identification Document Validation Technology (IDVT) service providers on our behalf including the results of identity, Right to Work and Disclosure and Barring Service (DBS) checks or other pre-employment screening
- The results of Right to Work or DBS checks
- A copy of your driving license.
We may also collect, store and use some types of more sensitive personal information such as information about your health, including any medical condition, health and sickness records where we are legally permitted to do so.
How Is Your Personal Information Collected?
We may collect personal information about candidates through the application and recruitment process from:
- You, and referees from details provided by you;
- Employment agencies or background check providers;
- Document Validation Technology (IDVT) service providers
- Your educational provider/relevant professional body;
- The Disclosure and Barring Service (DBS) and the Home Office.
How We Will Use Information About You
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- To take steps to enter into a contract.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
The situations in which we will process your personal information during the recruitment process are listed below:
- To assess your skills, qualifications, and suitability for the role
- Making a decision about your recruitment or appointment.
- Determining the terms on which you work for us.
- Checking you are legally entitled to work in the UK.
- To carry out background and reference checks, where applicable.
- Assessing your qualifications for a particular job or task.
- For assessing any education, training or development requirements.
- To communicate with you about the recruitment process.
- To keep records related to our hiring processes.
- To comply with legal or regulatory requirements.
Some of these grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers), engaging with you in the recruitment process, offering you a job or confirming an offer of employment.
Change of Purpose
- We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
- Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
“Special categories” of sensitive personal information (such as information relating to your race or ethnic origin, health, etc) require higher levels of protection. We need to have further justification for processing this type of personal information, which may include the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations and the processing is carried out in accordance with our data protection policy.
- Where it is needed to assess your capacity on health grounds where this is permitted by law and subject to appropriate confidentiality safeguards.
- We may also use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process.
Do we need your consent?
- We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. You should be aware that in circumstances where we do require your consent you are not required to agree to any request for consent from us.
Information about criminal convictions
- We envisage that we may process information about criminal convictions.
- We may only use information relating to criminal convictions where the law allows us to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process. We will use information about criminal convictions and offenses in order to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular, if the role requires a high degree of trust and integrity, for example where it involves working with any aspect of the financial services industry, we may ask you to seek a basic disclosure of your criminal records history. .
- We recognize the contribution that ex-offenders can make as employees. A person’s criminal record may not in itself prevent that person from being employed or engaged by us (except where the role relates to a regulated activity, in which case certain criminal records may mean you cannot be appointed to certain roles). Suitable applicants will not be refused employment or engagement because of offenses which are not relevant to, and do not place them at or make them a risk in, the roles which are available to them.
We are allowed to use your personal information in this way to carry out our legal obligations or with your explicit consent.
- We may have to share your personal information with other parties, including third-party service providers and other entities in the group where this is required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.
- “Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: IT services, Payroll and Accounting services, Legal and Professional services, Pension administration services, Benefits provision and administration services, recruiting services and certified Identification Document Validation Technology (IDVT) services,.
- All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with the GDPR. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. We may also need to share your personal information with a regulator or to otherwise comply with the law.
- We will not transfer your personal information outside the UK although in limited circumstances other entities within the group may have access to your personal information.
We have put in place measures to protect the security of your information and procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected breach where we are legally required to do so. Further details of our security measures are available upon request from the Head of UK Operations and HR.
Data Retention – How Long Will You Use My Information For?
- We will only retain the personal information that we obtain about you during the recruitment process (including interview notes) for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We also take into account the limitation periods for potential claims (as extended to take account of early conciliation). How long we keep this information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.
- In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
- If your application is not successful, your recruitment data will not normally be kept for longer than twelve (12) months, after which it will be securely destroyed. If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment and it will be processed in accordance with our employment data protection policies – copies of which will be provided at the start of your employment.
Rights of Access, Correction, Erasure, and Restriction
Your duty to inform us of changes
- Please keep us informed if your personal information changes during the recruitment process.
- Your rights in connection with personal information
- Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”).
- Request correction of the personal information that we hold about you.
- Request erasure of your personal information.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal information.
- Request the transfer of your personal information to another party.
- Right to withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
- If you want to exercise any of your data subject rights, please contact the Head of UK Operations and HR in writing.
- You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in these circumstances.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Transferring Information Outside the UK
- We do not transfer your personal information outside the UK. However, senior officers (currently the CEO and COO) in Bipsync’s US entity may have limited access to the personal information we collect about you and store on servers hosted in the UK. Your information is accessed and viewed in this way only to the extent that is necessary in order to make recruitment decisions or offers of employment.
- There is no adequacy decision by the European Commission in respect of the US. which means that itis not deemed to provide an adequate level of protection for your personal information. For this reason we do not transfer your information to servers hosted in the US.
- In compliance with the GDPR and Data Protection Act 2018 principles, Bipsync commits to resolve complaints about our collection or use of your personal information. UK individuals with inquiries or complaints regarding our policies should first contact Bipsync at: firstname.lastname@example.org.
- Bipsync’s US entity is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). There is the possibility, under certain conditions, for an individual to invoke binding arbitration. Bipsync is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Bipsync is liable in cases of onward transfers to third parties.
Data Protection Complaints
The Head of UK Operations and HR will oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Head of UK Operations and HR. If you are unhappy with the way we process your personal data then we would ask that you should contact our Head of UK Operations and HR in the first instance, who will investigate any complaint. However, if you remain unhappy following our response you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact: Charlotte White, Head of People and Operations on 02920099179 or email@example.com.