Faff-free Privacy Notice for Candidates
This Privacy Notice for Candidates applies to personal data related to your application and potential employment with cinch. This Privacy Notice applies to all candidates applying for a position in any of our UK offices.
Like any prospective employer, cinch needs to process personal data in order to run our business and manage our relationship with you, at all stages of the recruitment process. We do so in accordance with all applicable laws including the UK General Data Protection Regulation and Data Protection Act 2018.
1. This Privacy Notice explains:
Why we collect your personal data
What personal data is collected
How it is processed
Who receives it
Your legal rights to control its use.
This Privacy Notice only covers personal data processed during our recruitment processes. If you become an employee, then we will inform you separately about other purposes for which we may need to process personal data.
2. Who is the data controller for your data?
A ‘data controller’ is the organisation that decides on the purposes and ways that your personal data is processed. In our recruitment processes, these decisions are made by Cinch Cars Limited.
We have appointed a Data Protection Officer who can be contacted at:
Cinch Cars Limited, Form 2, 18 Bartley Wood Business Park, Bartley Way, Hook, Hampshire, RG27 9XA or by email: DPO-Office@cinch.co.uk
3. What types of personal data do we process?
‘Personal data’ - means any information which identifies and relates to you (or any other identifiable person). This may include:
Identity information, such as your name, date of birth, nationality, National Insurance number
Contact information, such as your address, email and telephone numbers
Other personal data we may collect, use and store includes:
Your CV, application letter, test results, application forms or online profiles (e.g. LinkedIn)
Records relating to your employment history, education, training and qualifications
Correspondence with or about you e.g. offer letters, references, etc.
Past, desired and possible compensation e.g. basic salary, benefits, pensions, bonuses, etc.
Tax status and IDs (once an offer of employment has been made)
Emergency contact details
Personal data needed for any equal opportunities monitoring policies
Criminal convictions
CCTV images and video footage may be recorded in our offices (e.g. when you attend an interview) for the purposes of maintaining the health and safety of employees and preventing crime and theft of property
Right to work information e.g. nationality, passport, ID card, visas, permits, etc
Driving licence (where applicable to the role)
Credit record (where applicable to the role e.g. with financial responsibility).
We may also collect, store and use 'special category data’ for certain narrowly defined purposes such as:
Health: Where necessary, and/or as required or permitted by the relevant legislation, we may keep personal data relating to your health, and any disabilities or medical conditions. This personal data will be used to comply with our health and safety and occupational health obligations – to consider how your health affects your ability to do a particular job and whether any adjustments to your tasks or the workplace or interview arrangements might be appropriate.
Equal opportunities monitoring: We may ask you for information relating to your racial or ethnic origin, disability status, religious and philosophical beliefs or sexual orientation. Any information provided by you for this purpose is anonymised and kept separate from your application.
The only other times we would process special category data are where this information is:
necessary for compliance with laws or carrying out employment-related rights and obligations
required to protect your health or safety in an emergency
something that you have made publicly available.
Much of the personal data we hold will have been provided by you, but some may come from other external sources, such as recruitment agencies, referees or medical professionals.
4. Why do we need to collect and process this personal data?
cinch will process and hold personal data relating to you:
where it is necessary to enter into a contract with you
where it is necessary for our legitimate interests (in managing our recruitment and ensuring we have a suitable range of skills and personnel for our business or to defend ourselves against legal claims)
to comply with applicable laws or regulations e.g. checking a successful applicant’s eligibility to work in the UK
to protect your health or safety in an emergency
in the case of equal opportunities monitoring data (see Section 3 above), where permitted by applicable laws.
5. Who receives your personal data?
We may transfer personal data about you to other cinch offices and affiliated companies for purposes connected with your recruitment application and HR management.
We use a third party data processor, Talos 360, to manage and track applications to cinch. cinch also works with other organisations that manage personal data in connection with our recruitment processes, such as IT and data processing, recruitment consultants, or other professional advisors. These organisations process personal data on our behalf, but our contracts with them oblige them to meet data protection standards as strict as the ones that apply to us, and not to use your data for any other purpose.
We operate within the UK. Some of our third party service providers may process personal data on our behalf in locations outside of the UK or EEA. When they do, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the UK or EEA do not have adequate data protection laws equivalent to those in the UK and EEA. If you would like more information about the safeguards we have in place, please contact our DPO using the details in Section 2.
At our discretion, we may disclose CCTV footage and/or personal data in response to valid requests from the police and other statutory law enforcement agencies or if otherwise required by law.
If you applied to cinch via a recruitment or employment agency then we may share with them general data about the progress of your application e.g. so that they can know whether you are no longer looking for a position.
6. How long do we keep your personal data?
Your personal data will be stored only for as long as it is needed for the purpose for which it was obtained.
We will keep job applicants’ and candidates’ personal data for not more than twelve months after the role has been filled (unless you ask or authorise us to keep it for longer). If you go on to be employed by cinch, your personal data will be transferred to your personnel file and retained in line with our employee privacy notice and retention policy.
7. What are your rights in relation to your personal data?
cinch is committed to ensuring that you can easily exercise your legal rights over your personal data. For example, you are entitled to ask at any time:
for access to a copy of the personal data that cinch holds about you
to have any incorrect personal data about you corrected.
You also have the right to ask us to erase your personal data (‘right to be forgotten’), to ask us to stop or restrict processing of your personal data, to object to us using your personal data, or to ask us to transfer your data to another data controller (‘right to data portability’). Please note that these rights only apply in certain circumstances, depending on the reason we are holding the data. Where we are unable to comply with your request fully or at all (e.g. because of our obligations under applicable employment laws), we will explain why not.
We are not usually required to ask for your consent in order for us to be able to process your personal data for the purposes set out in Section 4 of this Privacy Notice. However, where we do rely on any consent that you have given, then you are always allowed to withdraw your consent at any time (though the processing that took place before withdrawal will still be legal).
cinch can always be contacted at the addresses in Section 2 to resolve any issues or doubts you may have in relation to processing of your data or exercising your legal rights. If you believe that your rights have not been respected then you are also entitled to complain to the UK Information Commissioner (www.ico.org.uk) (or, if applicable to you, another Supervisory Authority) to ask them for a decision.
Where we received your personal data from a third party, such as a recruitment agency, you should refer to their privacy notice for information on how to assert your information rights in relation to the data they hold.
8. Consequences of not providing (or updating) data
Other than where we have asked for your consent for data processing, processing of personal data is necessary for the reasons explained in this Privacy Notice. If you object to processing of particular personal data relating to you, or require us to delete it, this could lead to us being unable to comply with the application process or other legal obligations. If so, we will tell you about the potential effects of our not having the required data in those circumstances.
Last updated: 17 June 2024