Appropriate Policy document
Walter Everett employment agency and consultancy and as such we must comply with the Data Protection act 1998 (superseded by the DPA 2018) and also GDPR. Because we process Special Category data if we place you in a job, and we are required by law to keep records, this is our Appropriate Policy Document as recommeded by the ICO, so you understand clearly how and why we store it/
What is Personal Data?
“‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
What is special category data
Some of the personal data you process can be more sensitive in nature and therefore requires a higher level of protection. The UK GDPR refers to the processing of these data as ‘special categories of personal data’. This means personal data about an individual’s:
religious or philosophical beliefs;
trade union membership;
biometric data (where this is used for identification purposes);
sex life; or
Why do we process special category data
By Law we are required to comply with The Employment Agencies Act 1973 and The conduct of Employment Agencies and Employment Businesses Regulations 2003 this means that we have to keep compliance documents such as passports, driving licences, offer including salary details for the people that we place, this can infer peoples race or ethnic origin. From the categories above only 1 and 2 apply . We do not collect data from 3 through to 10 unless you have openly disclosed information on you application documents. We follow the government guidance on recruitment agency records which can be found here: Right to Work Purposes:
What are our procedures to ensure compliance to the Law, GDPR and ICO principles. We also follow CAP guidance when placing adverts.
Security and technology
Our clients require that we send then documentation that proves you right to work in the UK, and proof of address. We store this data on the employment record within our secure ATS. This ATS merges with a password and VPN protected network and email account,
The Applicant Tracking System is also secure and password protected. The passwords are regularly changed. Access to the system is through encrypted PCs which again have another layer of Password protection.
Data Minimization, Security reviews with suppliers
As a company we try to keep our data at a minimum, We therefore only keep records that we are required to do by law to keep and when candidates have expressly agreed to having their CV on our database. We review this annually.
We work extensively with our ATS system to ensure that are data is kept securely. We discuss and review this with the provider every 3 months when we renew. They are also aware of their legal requirements to make us aware if their system was breached.
Retention and erasure policies
If you ask us to we will erase your data if we are not legally required to keep it. Its simple and easy just email firstname.lastname@example.org
APD review date - Jan 2022