Privacy Policy (Recruitment)

This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the application process. We are required to notify you of this information, under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

Who collects the information

Genmed.Me Limited (‘Company’) is a ‘data controller’ and gathers and uses certain information about you. This information is also used by our affiliated entities and group companies, namely Genmed Commercial Services Limited, Genmed Managed Services Limited and Genmed Group Limited (our ‘group companies’) and so, in this notice, references to ‘we’ or ‘us’ mean the Company and our group companies.

Data protection principles

We will comply with the data protection principles when gathering and using personal information, as set out in our Data Protection Policy (Employee).

About the information we collect and hold

Part A of the notice below summarises the information we collect and hold up to and including the shortlisting stage of the recruitment process, how and why we do so, how we use it and with whom it may be shared.

Part B of the notice below summarises the additional information we collect before making a final decision to recruit, i.e., before making an offer of employment unconditional, how and why we do so, how we use it and with whom it may be shared.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

Where information may be held

Information may be held at our offices and those of our group companies, and third-party agencies, service providers, representatives and agents as described above.

How long we keep your information

We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your 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.

We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised, and the longer period for which they will be kept.

If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment. For further information, see Data Protection Privacy Policy (Employee).

Your right to object to us processing your information

Where our processing of your information is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your information unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

Please contact our Data Protection Officer (DPO) (dataprotection@genmed.eu) if you wish to object in this way.

Your rights to correct and access your information and to ask for it to be erased

Please contact our DPO, (dataprotection@genmed.eu) if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask our Data Protection Officer for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. Our DPO will provide you with further information about the right to be forgotten, if you ask for it.

Keeping your personal information secure

We have appropriate security measures in place 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.

How to complain

We hope that our DPO can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

Part A – Up to and including the shortlisting stage

The information we collect

Your name and contact details

We collect this information from you
We collect this information to carry out a fair recruitment process and to progress your application, arrange interviews and inform you of the outcome at all stages (legitimate interest)
HR personnel will share the information with the relevant manager of the department of your application

Details of your qualifications, experience, employment history and interests

We collect this information from you
We collect this information to carry out a fair recruitment process and to make an informed decision to shortlist for interview and, if relevant, to recruit (legitimate interest)
The person making the shortlisting decision will receive pseudonymised or anonymised details only; if you are invited for an interview, the interviewer will receive non-anonymised details

Part B – Before making a decision to recruit

The information we may collect (depending on the role)

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

We collect this from your referees using the details you will have provided
We collect this information to make an informed decision to recruit you, to comply with our legal obligations and to maintain employment records and good employment practice (legitimate interest)
We may share this information with relevant managers and HR personnel

Information regarding your academic and professional qualifications

We collect this information from you, your education provider and from the relevant professional body
We collect this information to verify the qualifications information provided by you
We may share this information to make an informed recruitment decision

Information regarding your criminal record, in a criminal records certificate (CRC) or enhanced criminal records certificates (ECRC) as appropriate (together with proof of address and identity)*

We collect this information from you via the Disclosure and Barring Service (DBS) check run through an umbrella company contracted by us
We collect this information to perform the employment contract, to comply with our legal obligations and for reasons of substantial public interest (preventing or detecting unlawful acts and protecting the public against dishonesty)
We may share this information to make an informed recruitment decision and may share information with DBS and other regulatory authorities as required

Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information

We collect this information from you
We collect this information to perform the employment contract, to comply with our legal obligations, to maintain employment records and to carry out obligations and exercise rights in employment law
We may use this information to carry out right to work checks and may share the information with the Home Office

A copy of your driving licence and DVLA check code

We collect this information from you
We collect this information to perform the employment contract, to comply with our legal obligations and to comply with the terms of our insurance (where applicable)
We may use this information to make an informed recruitment decision, to ensure that you have a clean driving licence and may share information with our insurer

Details of your referees

We collect this information from the application form you completed
We collect this information to carry out a fair recruitment process (legitimate interest)
We may share this information with relevant managers, HR personnel and the referee

* Further details on how we handle sensitive personal information and information relating to criminal convictions and offences are set out in our Data Protection Privacy Policy (Employee) and our Criminal Records Policy, available from the HR department.