Privacy notice (job applicants)

Purpose of this Policy

At Travel Counsellors we respect the privacy of individuals and are committed to protecting the privacy and security of your personal information. As part of our recruitment process, we will need to collect and process personal information about you. In this privacy notice, we explain how we collect and use information about you when you apply for a job with us.

Our role

We are Travel Counsellors Limited based at Venus No1 Old Park Lane, Trafford City, Manchester, England, M41 7HA (registered company number: 02133414) (“Travel Counsellors”, “we”, “us”, “our”). We are the “controller” under data protection legislation of any personal data that we process about you, including where we receive it from a recruitment agency. This means that we are responsible for deciding how we hold and use personal information about you.

If you have any questions about your privacy, your rights or our use of your personal data, please contact the data protection team at dpo@travelcounsellors.com.

Data protection principles

We will comply with data protection law, which says that the personal information that we hold about you must 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.

Personal information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include any data where the person’s identity has been removed (anonymous data). Some types of more sensitive personal data require a higher level of protection such as information about an individual’s health or criminal convictions.

You are not required (by law or by any contract with us) to provide personal information to us. However, it is necessary for us to collect personal data about you if you wish to apply for a job with us, so that we can progress your application.

The information that we are likely to collect during our recruitment process includes:

• Your identity and contact details (e.g., full name and title, email, phone numbers and postal address).
• Your CV and information about your skills, qualifications, experience and employment history (including information about your current remuneration and employee benefits, if you choose to provide this information to us).
• Records of our interviews with you and your progression through our recruitment process.
• Results of your AVA personality evaluation and other recruitment exercises.
• Copies of any correspondence with you during the application and recruitment process.
• Whether or not you have a disability for which we may need to make reasonable adjustments during our recruitment process.
• Information about criminal convictions and offences.

If your application is successful and we offer you a role with us, we will also collect the following information:

• Information about your right to work in the UK (e.g. a copy of your passport).
• References from your previous employers (we will not contact your current employer unless you give us permission to do so).
• Qualification certificates (if relevant).
• Information for equal opportunities monitoring, including your age, disabilities, marriage/civil partnership status, sex, gender, ethnic origin, sexual orientation, health and religion or belief.
• Other information we may require from you depending on the role you apply for, such as details of any DBS (Disclosure and Barring Service) checks or other background checks.
• CCTV footage where you attend at our premises for an interview.

We may collect this information directly from you (e.g. in your CV and other documents that you may provide to us) or we may collect it from third parties such as recruitment agencies and personality evaluation providers. Unsolicited approaches from recruitment agencies will not be considered without our prior written agreement. Where information is provided by a recruitment agency, including on an unsolicited basis, we expect all recruitment agencies to have obtained the candidate’s consent prior to sharing this information with us and to be compliant with applicable laws.

If we need to conduct DBS or other background checks, we may collect this data from third parties. If we do, we will inform you and explain how we intend to use it.

How we will use information about you

Assessing your suitability for the role

We use the information that we collect about you to assess your suitability for the role that you have applied for and to effectively manage our recruitment process.

It is necessary for us to process information about you in this context in order to take steps, at your request, towards potentially entering into a contract for employment with you. We also have a legitimate interest in assessing your suitability for the role in comparison to other candidates, and in order to do this it is necessary for us to process information about, for example, your skills, qualifications and experience as well as the information that we collect during interviews.

Depending on the type of role you apply for, prior to confirming that you are successful in your application, we may also conduct DBS and other background checks to ensure your suitability.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

Complying with legal obligations

During the recruitment process, we may be required to process your personal information in order to comply with our legal obligations. This may include for conducting checks to ensure that you have the right to work in the UK or for processing information about your health or disabilities in order to make any reasonable adjustments that may be necessary.

Security and protection of our business

During the recruitment process, we may also collect and process information about you to protect our business premises and personnel, such as CCTV recordings.

We may also need to process your personal information for the purposes of responding to and defending legal claims.

Equal Opportunities Monitoring

We may collect information about your age, disabilities, marriage/civil partnership status, sex, gender, ethnic origin, sexual orientation, health and religion or beliefs for the purpose of equal opportunities monitoring.

Information that we request for equal opportunities monitoring purposes will be recorded anonymously and is not stored in a way which could be linked or connected to you. The provision of information as part of our equal opportunities monitoring is entirely voluntary and you may choose not to respond to some or all of the questions we ask in connection with equal opportunities monitoring activities. We aggregate this data with responses provided by other job applicants to allow us to monitor the demographics of those applying for roles at Travel Counsellors, as part of our efforts to combat discrimination.

Protecting your personal information

We will share your personal information internally with our staff for the purposes of conducting the recruitment exercise, but this is limited to those individuals who need to access your data (including, for example, our People team, interviewers, managers and IT and other support teams). We also use a third party software platform for our recruitment activities. Access to our recruitment portal is governed by this privacy policy, as well as the portal terms and conditions and the privacy policy of our third party supplier which is available upon accessing the portal.

If your application is successful and we make you an offer of employment which you accept, we may share your personal information with relevant third parties such as:

• Your previous employers to obtain references (we will not contact your current employer unless you give us permission to do so).
• Our internal health and safety team or occupational health providers if we need to make reasonable adjustments for you or if you have any health condition that may affect your ability to perform your duties or place you at risk in the workplace.
• Our HR management software company and other IT and communication providers to set you up on our systems.

We have in place appropriate security measures to protect the security of your information and to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

How long do we keep your information for

We will keep the information that we collect about you throughout the recruitment process and for a period of 6 months afterwards. You may however choose to allow us to keep your data for a period of up to 12 months instead, so that we can consider you for similar roles that become available where you are unsuccessful at first attempt. After this period, all personal information we hold about you will be erased or destroyed.

If your application is successful and you accept an offer of employment, we will transfer the information we hold about you to your personnel file which will be retained throughout the period of your employment with us. We will provide you with a separate Colleague Privacy Notice which explains how we process your personal data as an employee.

Your rights

You have a number of rights in respect of your personal data, which are summarised below. You can also find more information on your rights set out on our Privacy Notice on our website. If you would like to exercise any of your rights, please contact DPO@travelcounsellors.com.

• You have the right to be informed about our use of your personal data.
• You have the right to access information about, and copies of, the personal data that we hold about you.
• You have the right to ask us to rectify any incorrect or incomplete data we hold about you.
• In certain circumstances, you may have the right to ask us to erase data we hold about you.
• You may have the right to ask us to transfer your data to you or a third party in a common electronic format.
• You have the right to object to our use of your data for direct marketing purposes, or in reliance on our legitimate interests. Our legitimate interests are explained in this notice.
• In certain circumstances, you may have the right to ask us to restrict how we use your data.
• You have the right not to be subject to significant decisions made based purely on automated decision-making (note, we do not use automated decision-making in our recruitment procedure).

Contact Us

You always have the right to make a complaint to the supervisory authority, the Information Commissioner’s Office (ICO), which you can do on the ICO website. However, if you would like to raise any issues about our collection or use of your personal data, we would appreciate hearing from directly in the first instance so that we may seek to resolve your issue.

If you do wish to raise a complaint, or speak with us regarding your privacy or our use of your personal data, you can contact us at DPO@travelcounsellors.com or write to us at DPO, Travel Counsellors Limited, Venus No1 Old Park Lane, Trafford City, Manchester, England, M41 7HA.