Job Applicant Privacy Notice

Cool Earth is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This Job Applicant Privacy Notice sets out what personal data we, Cool Earth, hold about you and how we collect and use it during and after the recruitment process. It applies to anyone who is applying to work for us, whether as an employee, worker, contractor, consultant, intern, volunteer, partner or director (together referred to as ‘Job Applicant’ or ‘you’).

If you have any questions or concerns about how your personal data is being used by us, you can contact by email on [email protected] or telephone 01326 567200.

Note too that 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. Details of how to contact the ICO can be found on their website: https://ico.org.uk

Data controller details

Cool Earth is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: Cool Earth, Tremough Innovation Centre, Penryn TR10 9TA; Telephone 01326 567200.

Data protection principles

In relation to your personal data, we will:

  • process it fairly, lawfully and in a clear, transparent way
  • collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
  • only use it in the way that we have told you about
  • ensure it is correct and up to date
  • keep your data for only as long as we need it
  • process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed

Types of data we process

We may hold many types of data about you, including:

  • your personal details including your name, address, date of birth, email address, phone numbers
  • gender
  • marital status
  • whether or not you have a disability
  • information included on your CV including references, education history and employment history
  • documentation relating to your right to work in the UK

How we collect your data

We collect data about you in a variety of ways including the information you would normally include in a CV or a job application cover letter, or notes made by our recruiting officers during a recruitment interview. Further information will be collected directly from you when you complete forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.

Personal data is kept in personnel files or within the Company’s HR and IT systems.

Why we process your data

The law on data protection allows us to process your data for certain reasons only:

  • in order to perform the employment contract that we are party to
  • in order to carry out legally required duties
  • in order for us to carry out our legitimate interests
  • to protect your interests and
  • where something is done in the public interest.

All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.

We need to collect your data to ensure we are complying with legal requirements such as:

  • Pre-employment check information, including references and verification of qualifications
  • carrying out checks in relation to your right to work in the UK and
  • making reasonable adjustments for disabled employees.

We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:

  • process your application and correspond with you about it;
  • assess whether you have the required skills, experience, qualifications and training for 
a role within the company;
  • making informed decisions about who to offer employment to
  • making decisions about salary and other benefits
  • assessing training needs
  • verify information provided by you;
  • dealing with legal claims made against us
  • keep appropriate records of our recruitment process and decisions

Special categories of data

Special categories of data are data relating to your:

  • health
  • sex life
  • sexual orientation
  • race
  • ethnic origin
  • political opinion
  • religion
  • trade union membership and
  • genetic and biometric data.

We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:

  • you have given explicit consent to the processing
  • we must process the data in order to carry out our legal obligations
  • we must process data for reasons of substantial public interest
  • you have already made the data public.

We will use your special category data:

  • for the purposes of equal opportunities monitoring
  • adjustments for disability/ medical conditions

We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

If you do not provide your data to us

One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not able to process, or continue with (as appropriate), your application.

Sharing your data

Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties with regard to recruitment. This includes, for example, HR and recruitment teams, those in the department where the vacancy is, those who are responsible for screening your application and interviewing you, the IT department where you require access to our systems to undertake any assessments requiring IT equipment and to the administrative teams responsible for contacting you.

In some cases, we will collect data about you from third parties, such as employment agencies.

Your data will be shared with third parties if you are successful in your job application. In these circumstances, we will share your data in order to obtain references as part of the recruitment process.

We do not share your data with bodies outside of the European Economic Area during the normal processes of recruitment unless your recruitment relates to working with our in-country teams outside the UK (currently the US, PNG, and Peru). Should there be a need to transfer your data outside of the EEA area, this will be managed as an inter-organisational transfer which means the data will not leave Cool Earth’s systems and Cool Earth’s data protection policies apply throughout.

We have put measures in place to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred process it in a way required by EU and UK data protection laws.

Protecting your data

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such, including Data Protection policies and training.

Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

How long we keep your data for

If your application is not successful we will keep your data for up to six months once the recruitment exercise ends or from the date we notify you of our decision.

If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.

Your rights in relation to your data

The law on data protection gives you certain rights in relation to the data we hold on you. These are:

  • the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
  • the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
  • the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
  • the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
  • the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
  • the right to portability. You may transfer the data that we hold on you for your own purposes
  • the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
  • the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please write to us at Cool Earth, Tremough Innovation Centre, Penryn TR10 9TA. Note that these rights are not absolute and in some circumstances, we may be entitled to refuse some or all of your request.

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