Privacy notice for recruitment
The Telegraph Media Group (“TMG”, “We”, “Us”) comprises Telegraph Media Group Limited and Press Acquisitions Limited. As part of our candidate application and recruitment activities we collect, process and store personal and special categories of data (together “personal information”) which may directly or indirectly identify a Candidate (“Candidate,” “You,” or “Your”). We process personal information for the recruitment process and this may include your application, assessment, and pre-employment screening.
This Recruitment Privacy Notice (“Privacy Notice”) sets out:
● how we collect your personal information;
● what information is collected and;
● how it is processed within the recruitment process.
● The lawful bases for the use of your personal information
● Your rights in relation to your personal information
● How to contact us.
How do we collect your information?
Most of the personal information that we process is provided to us directly by you when you apply for a job or for work experience with us either directly or via a recruiter. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.
What personal information is collected?
● Personal details such as name, address, email address and date and place of birth;
● Work history/job data; previous employers, positions, dates;
● Compensation; basic salary, benefits, bonuses, etc.;
● Education and work history including professional qualifications and skills;
● Employer feedback / references, to include regulated references where necessary;
● Nationality / visa / right to work permit information; (e.g. passport, driving licence, National Insurance numbers);
● Photographs and images from recorded assessments or from on-site CCTV;
● Results of pre-employment screening checks (e.g. adverse, criminal records checks where permitted/required for specific roles);
We may also collect, store and use some or all of the following types of more sensitive personal information:
● Information about your gender, sexual orientation, marital status, religion, disability, and ethnic origin to help us monitor Diversity and Inclusion at TMG. The provision of this information is optional and can be deleted upon your request. This information will not be used in the selection process.
● Information about criminal convictions and offences if a Basic Criminal Records Check is required for the role being applied for. The requirement for such checks will be made clear early in the application process and are also subject to the TMG Policy on the Recruitment of Ex-Offenders.
● Information about your health, including any medical condition, health and sickness records.
Information we collect from other sources
● Where required as a condition of employment, we may receive information from the Disclosure Barring Service on unspent criminal convictions, and on bankruptcy, Individual Voluntary arrangements and County Court Judgements as part of our background screening processes.
● References may be collected from past employers.
● We may receive your personal information from a third party who recommends you as a candidate for a specific job opening or for Our business more generally.
How we use your information in the recruitment process
We use information held about you in the following ways:
● To consider your application in respect of a role for which you have applied.
● To consider your application in respect of other roles.
● To communicate with you in respect of the recruitment process.
● To enhance any information that We receive from you with information obtained from third party data providers, such as recruitment agencies.
● To allow us to monitor Diversity of applicants (this information will not be used in the selection process).
● To find appropriate candidates to fill Our job openings.
● To help Our service providers (such as Workable and its processors and data providers) and Partners (such as the job sites through which you may have applied) improve their services.
● To conduct background checks where the role requires it, such as Adverse Credit Checks and Basic Criminal Records Checks.
Lawful basis for processing
Data protection laws require us to explain the lawful basis for the use of the personal information that we collect.
a) We will process your personal information where it is necessary for entry into or the performance of the employment contract. For example, when you apply for a role;
b) We will also process your personal information where it is required by law or regulation, for example health and safety laws, employment or tax laws, equalities laws and laws and regulations intended to prevent and detect crime;
c) We will process your personal information where it is in our legitimate interests such as for general research activities to support our recruitment initiatives. This processing will always be fair and lawful and will at all times comply with the principles of privacy law;
d) During the course of your application, it may also be necessary for Us or our suppliers to process your special categories of information (including information about criminal convictions or offences). This processing will only be carried out where permitted and: i. where you have provided your explicit consent; or ii. where necessary to comply with employment law obligations such as making reasonable adjustments to ensure compliance with the Equality Act 2010.
Criminal Record Checks
To ensure that the people we employ in specific roles or departments with access to financial systems or with Senior Management responsibilities are a trusted member of the TMG workforce, we may conduct criminal record checks consistent with applicable law. If a role requires a Criminal Records Check you will be notified of this early in the recruitment process, but a check would only be made when offered a position. Should you not consent to the check taking place it is likely that a job offer would be withdrawn.
Sharing your information
Your personal information may be shared internally within TMG with the following people:
● Those employees who would have managerial responsibility for you or are acting on their behalf;
● Employees in HR who have responsibility for certain HR processes (for example, recruitment, assessment, pre-employment screening);
● Employees in IT and system owners who manage user access;
● Audit and Investigations employees in relation to specific audits/investigations; and
● Security managers for our Office.
Our data processors
We use Workable, an online application process provided by Workable Software Limited, to assist with Our recruitment process. We use Workable to process personal information as a data processor on Our behalf. Workable is only entitled to process your personal information in accordance with Our instructions. We may also suppliers to help us manage background screening and Criminal Records Checks.
Automated decision making/profiling
We may use Workable’s technology to select appropriate candidates for Us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who We will engage to fill the job opening will be made by Our staff.
How We store your personal information
We take appropriate measures to ensure that all personal information is kept secure including security measures to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so. Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal information.
Where We store your personal information
When We store your personal information in Our own systems, it is stored in the United Kingdom. The data that We collect from you and process using Workable’s Services may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers. By submitting your personal information, you agree to this transfer, storing or processing.
In particular, your data may be accessible to i) Workable’s staff in the USA or ii) may be stored by Workable’s hosting service provider on servers in the USA as well as in the EU. The USA does not have the same data protection laws as the United Kingdom and EEA. A Data Processor Agreement has been signed between Workable Software Limited and its overseas group companies, and between Workable Software Limited and each of its data processors. These data processor agreements are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. If you would like further information please contact Us (see ‘Contact’ below).
How long We keep your personal information
We will hold recruitment data for 6 months. Should you become an employee, information may be retained as part of your Employee file and will then be subject to TMG’s Human Resources Retention Policy. Your personal information may be deleted on one of the following occurrences:
● deletion of your personal information by you (or by another person engaged by the Customer); or
● If we receive a written request by you (or another person engaged with your authority) to us, we will consider whether we can delete the data.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
● access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
● require Us to correct any mistakes in your information which We hold
● require the erasure of personal information concerning you in certain situations
● receive the personal information concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
● object at any time to processing of personal information concerning you for direct marketing
● object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
● object in certain other situations to Our continued processing of your personal information
● otherwise restrict Our processing of your personal information in certain circumstances
● claim compensation for damages caused by Our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
● contact Us using Our Contact details below,
● let Us have enough information to identify you,
● let Us have proof of your identity and address, and
● let Us know the information to which your request relates.
Questions and comments regarding this Privacy Notice and rights requests should be addressed to the Data Protection Officer by email email@example.com or by post to: Data Protection Officer, Data Protection Officer, 111 Buckingham Palace Road, London SW1 0DT.
How to complain
We hope that We can resolve any query or concern you raise about Our use of your personal information. However if you are not satisfied with how we have dealt with your enquiry/complaint you make a complaint with a supervisory authority. The supervisory authority for data protection in the UK is the Information Commissioner whose contact details can be found at http://ico.org.uk/concerns/ or by telephone: +44303-123-1113.
Last Updated: 04.05.2023