Job Applicant Data Policy

This document sets out the Company’s policy on the protection of information relating to job applicants. Protecting the confidentiality and integrity of personal data is a critical responsibility that the Company takes seriously at all times. The Company will ensure that data is always processed in accordance with the provisions of relevant data protection legislation, including the General Data Protection Regulation (GDPR).

Key Definitions

Data processing

Data processing is any activity that involves the use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring personal data to third parties.

Personal data

Personal data is any information identifying a data subject (a living person to whom the data relates). It includes information relating to a data subject that can be identified (directly or indirectly) from that data alone or in combination with other identifiers the Company possesses or can reasonably access. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour.

Sensitive personal data

Sensitive personal data is a special category of information which relates to a data subject’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data. It also includes personal data relating to criminal offences and convictions.

Privacy Notice

This policy, together with the information contained in the table of applicant data appended to the policy, constitutes a privacy notice setting out the information the Company holds about applicants, the purpose for which this data is held and the lawful basis on which it is held. The Company may process personal information without applicants’ knowledge or consent, in compliance with this policy, where this is required or permitted by law.

If the purpose for processing any piece of data about applicants should change, the company will update the table of applicant data with the new purpose and the lawful basis for processing the data and will notify applicants.

Fair Processing of Data

Fair processing principles

In processing applicants’ data, the following principles will be adhered to. Personal data will be:

Used lawfully, fairly and in a transparent way;
Collected only for valid purposes that are clearly explained and not used in any way that is incompatible with those purposes;
Relevant to specific purposes and limited only to those purposes;
Accurate and kept up to date;
Kept only as long as necessary for the specified purposes; and
Kept securely.

Lawful processing of personal data

Personal information will only be processed when there is a lawful basis for doing so. Most commonly, the Company will use personal information in the following circumstances:

when it is needed to perform applicants’ contracts of employment;
when it is needed to comply with a legal obligation; or
when it is necessary for the Company’s legitimate interests (or those of a third party) and applicants’ interests and fundamental rights do not override those interests.

The Company may also use personal information in the following situations, which are likely to be rare:

when it is necessary to protect applicants’ interests (or someone else’s interests); or
when it is necessary in the public interest or for official purposes.

Lawful processing of sensitive personal data

The Company may process special categories of personal information in the following circumstances:

In limited circumstances, with explicit written consent;
in order to meet legal obligations;
when it is needed in the public interest, such as for equal opportunities monitoring or in relation to the Company’s occupational pension scheme; or
when it is needed to assess working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, the Company may process this type of information where it is needed in relation to legal claims or where it is needed to protect an applicant’s interests (or someone else’s interests) and the applicant is not capable of giving consent, or where an applicant has already made the information public. The Company may use particularly sensitive personal information in the following ways:

information relating to leaves of absence, which may include sickness absence or family related leaves, may be used to comply with employment and other laws;
information about applicants’ physical or mental health, or disability status, may be used to ensure health and safety in the workplace and to assess fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.

Lawful processing of information about criminal convictions

The Company will hold information about criminal convictions and will only use this information where it has a legal basis for processing the information. This will usually be where such processing is necessary to carry out the Company’s obligations. Less commonly, the Company may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect an applicant’s interests (or someone else’s interests) and the applicant is not capable of giving consent, or where the applicant has already made the information public.

The Company will only collect information about criminal convictions if it is appropriate given the nature of the role and where it is legally able to do so.

Consent to data processing

The Company does not require consent from applicants to process most types of applicant data. In addition, the Company will not usually need consent to use special categories of personal information in order to carry out legal obligations or exercise specific rights in the field of employment law.

In limited circumstances, applicants may be asked for written consent to process sensitive data. In those circumstances, applicants will be provided with full details of the information that is sought and the reason it is needed, so that applicants can carefully consider whether to consent.

Where applicants have provided consent to the collection, processing and transfer of personal information for a specific purpose, they have the right to withdraw consent for that specific processing at any time. Once the Company has received notification of withdrawal of consent it will no longer process information for the purpose or purposes originally agreed to, unless it has another legitimate basis for doing so in law.

Automated decision making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.

The Company does not envisage that any decisions will be taken about applicants using automated means, however applicants will be notified if this position changes.

Collection and Retention of Data

Collection of data

The Company will collect personal information about applicants through the application and recruitment process, either directly from candidates or sometimes from an employment agency. The Company may sometimes collect additional information from third parties including former employers.

From time to time, the Company may collect additional personal information from an applicant. If the Company requires to obtain additional personal information this policy will be updated or applicants will receive a separate privacy notice setting out the purpose and lawful basis for processing the data.

Retention of data

The Company will only retain applicants’ personal information for as long as necessary to fulfil the purposes it was collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of personal information are set out in the table of applicant data appended to this policy.

When determining the appropriate retention period for personal data, the Company will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which the personal data is processed, whether the Company can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, the Company may anonymise personal information so that it can no longer be associated with individual applicants, in which case the Company may use such information without further notice to applicants. After the data retention period has expired, the Company will securely destroy applicants’ personal information.

Data Security and Sharing

Data security

The Company has put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Details of these measures are available upon request.

Data sharing

The Company may share personal information with third parties. The Company requires third parties to respect the security of applicant data and to treat it in accordance with the law. The Company may also need to share personal information with a regulator or to otherwise comply with the law.

The Company may also share applicant data with third-party service providers where it is necessary to administer the working relationship with applicants or where the Company has a legitimate interest in doing so. The following activities are carried out by third-party service providers: pension administration, benefits provision and administration, IT services.

Staff Member Rights and Obligations

Accuracy of data

The Company will conduct regular reviews of the information held by it to ensure the relevancy of the information it holds. Applicants are under a duty to inform the Company of any changes to their current circumstances. Where an Applicant has concerns regarding the accuracy of personal data held by the Company, the Applicant should contact the Recruitment and Training Manager to request an amendment to the data.

Applicant rights

Under certain circumstances, applicants have the right to:

Request access to personal information (commonly known as a “data subject access request”).
Request erasure of personal information.
Object to processing of personal information where the Company is relying on a legitimate interest (or those of a third party) to lawfully process it.
Request the restriction of processing of personal information.
Request the transfer of personal information to another party.

If an applicant wishes to make a request on any of the above grounds, they should contact the Recruitment and Training Manager in writing. Please note that, depending on the nature of the request, the Company may have good grounds for refusing to comply. If that is the case, the applicant will be given an explanation by the Company.

Data subject access requests

Applicants will not normally have to pay a fee to access personal information (or to exercise any of the other rights). However, the Company may charge a reasonable fee if the request for access is clearly unfounded or excessive. Alternatively, the Company may refuse to comply with the request in such circumstances.

The Company may need to request specific information from the applicant to help confirm their identity and ensure the right to access the information (or to exercise any of the other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Compliance with this Policy

The Company’s responsibility for compliance

The Company has appointed a data protection officer (DPO) who is tasked with overseeing compliance with this policy. If applicants have any questions about this policy or how the Company handles personal information, they should contact the DPO. Applicants 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.

Data security breaches

The Company has put in place procedures to deal with any data security breach and will notify applicants and any applicable regulator of a suspected breach where legally required to do so. Details of these measures are available upon request.

Updated 28th April 2020

This Privacy Policy sets out how Singula Decisions Limited (“Singula Decisions”) uses and protects any information that you may provide to us when you use our website, products and services.

We respect your rights and privacy; we are committed to ensuring that any information gathered on our website, and/or via our products and services, is kept confidential and is only used in the ways which you have consented to.

Should we ask you to provide certain information, by which you can be identified when using our website, products and services, then you can be assured that it will only be used in accordance with this privacy policy and in line with the EU General Data Protection Regulations (“GDPR”).

We will not store data for longer than necessary and use it only for the purpose that it was gathered.

You should check the Privacy Policy to ensure that you are happy with the terms. If you are not happy with the terms, please do not enter any personal data.

Singula Decisions will regularly review this Privacy Policy and make changes when necessary. If we make any significant changes to this Privacy Policy, we will communicate these to you, as applicable.

WHAT DATA WE COLLECT

Information is captured via our website contact form or marketing campaign landing pages, as well as via our relevant products and services. This data is provided by you voluntarily.

We may collect and store the following information, as applicable:

Name (e.g. first name and surname);
Contact information (e.g. e-mail address and telephone number(s));
Demographic information (e.g. country, preferences and interests);
Business metrics (e.g. subscriber numbers, churn rate, average revenue per user, etc.); and
IP address and web activity (e.g. web pages visited, time spent on the website, etc.).

WHAT WE DO WITH THE INFORMATION WE GATHER

Singula Decisions requires the information to understand your needs and to provide you with the relevant service. We use the information for the following reasons:

Internal record keeping;
To improve relevant products and services;
To periodically send promotional communications (electronic and telephone) about new products and services, thought leadership or other information which we think you may find interesting based on the information that you have provided;
To contact you for market research purposes; and
To customise our website based on the interests you have indicated.

We may share relevant information with trusted third parties. We do not share data outside of the European Economic Area (“EEA”) unless a specific arrangement is in place to do so between the relevant parties.

WHERE IS DATA STORED?

We use a third-party provider, HubSpot, to capture and store data. This is done securely and in line with the requirements of the GDPR.

SECURITY

Singula Decisions is committed to ensuring that the information you provide is secure. To prevent unauthorised access or disclosure, we have implemented suitable physical, electronic and managerial procedures to safeguard and secure the information we collect and store.

PURPOSE OF PROCESSING YOUR DATA

Personal information provided by you is used to promote our products and services. We also promote items that may be of interest (e.g. company announcements, thought leadership, case studies, new partnerships, and events we are attending).

We can segment our promotional communications based on a range of factors (e.g. your consented preferences and the information you have provided).

In general, marketing campaigns are promoted by e-mail and from time-to-time by telephone.

CONSENT

With effect from the 25th May 2018, we provide a mechanism to facilitate consent to receiving relevant communications from us.

When you complete any website form or marketing campaign landing page on our website you will be asked to check two boxes to provide your consent:

To receiving marketing communications from us; and

That you have read and accept this Privacy Policy.

You can withdraw your consent at any time by sending an email to info@singuladecisions.com or by clicking the “unsubscribe” link in any e-mail received from Singula Decisions.

CONTROLLING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of your personal information in the following ways:

Whenever you are asked to fill in a form on our website; identify the marketing consent statement allowing you to select the box to indicate that you accept or reject your information to be used for direct marketing purposes; and

If you have previously agreed to us using your personal data for direct marketing purposes, you may change your mind at any time by withdrawing your consent as detailed above.

Singula Decisions will not sell, distribute or lease your personal information to third parties unless we have your express permission or are required by law to do so. We may use your personal data to send you promotional information about selected third parties if you have selected that you are happy to receive marketing communications.

You may request details of personal information that we hold about you by contacting us in writing (FAO Data Protection Officer, Singula Decisions Limited, Cluny Court, John Smith Business Park, Kirkcaldy, Fife KY2 6QJ) or by emailing dpo@singuladecisions.com.

If you believe that any information that we are holding on you is incorrect or incomplete, please contact us in writing or by email as soon as possible. We will promptly correct any information found to be incorrect.

Data Subject Rights

Singula Decisions has a nominated Data Protection Officer (“DPO”), with responsibility for managing Singula Decisions’ policies, procedures and practices in relation to data protection. Contact, for any purposes (e.g. to complain, to request details of information held, etc.) can be made to the DPO in writing using the Singula Decisions address above or by emailing dpo@singuladecisions.com.

In compliance with the GDPR, you can contact us to:

Right to Subject Access Request (Article 15) – to request a report of the data that we hold on you;
Right to Rectification (Article 16) – to request us to update inaccurate/incomplete data that we hold on you;
Right to Erasure (Article 17) – to request us to remove your data from our systems (NB: in this instance, we will likely anonymise your data);
Right to Restriction of Processes (Article 18) – to request that we do not process incorrect data or where you have withdrawn consent for use;
Right to Receive Personal Data (Article 201) – to request that your data is provided to you to allow you to pass it to another company (this will be in a commonly used, machine-readable, format); and
Right to Object (Article 21) – to allow you to object to us holding your data where you believe we have no reason to hold it.

You may also contact our DPO if you wish to make a complaint. Contact can be made in writing, to the address set out above, or by email to dpo@singuladecisions.com.

LINKS TO OTHER WEB SITES

The Singula Decisions website may contain links to other websites of interest. Please note that if you use these links to leave our site that we have no control over the other website, therefore cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and we recommend that you review their separate privacy notices, as applicable.

HOW WE USE COOKIES

A cookie is a small file which asks permission to be placed on your computer’s hard-drive. Once you agree, the file is added and the cookie helps to analyse web traffic and when you have visited a particular site.

Cookies allow web applications to respond to you as an individual based on your interactions. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Overall, cookies help us to provide you with a better website experience, by enabling us to monitor which pages you find useful and which you do not.

A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies.

Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies. However, if you decline cookies, this may prevent you from taking full advantage of our website, products and services.

Please read our Cookie Policy for more information by clicking this link.

This Privacy Policy is effective from 28th April 2020.

Cookie Policy

Cookie policy
Updated 28th April 2020

This Cookies Policy describes how Singula Decisions Limited (“Singula Decisions”) uses different types of cookies on the Singula Decisions website; explaining how they are used and how you can control cookies.

ABOUT COOKIES

Cookies are small data files stored on your computer containing information which recognises you if you return to a website. Cookies help us to customise your experience and helps users to navigate and stores their user preferences. You may reject to accept cookies by activating the appropriate session on your browser, however by doing so, some features on the website may not work as intended. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.

OUR USE OF COOKIES

When you visit the Singula Decisions website, we may collect information automatically using cookies. Most of the information cookies collect does not personally identify you, but does include information such as IP address, operating systems and viewing behaviour. To the extent that any personal information is collected through cookies, our Privacy Policy applies to how we use and store this data.

TYPES OF COOKIES WE USE

Site Management Cookies

These cookies are used to maintain your identify or session on the website. These are designed to enhance the website functionality and without them, it will not perform as smoothly for you as we would like, and we may not be able to provide certain features.

Analytics Cookies

Analytics cookies collect information about your use of the website. These track and monitor, for example, how visitors move around the website, how they reached the website and time spent on pages. Analytics cookies are not essential for our website to work. Our analytics cookies include Google, which you can find out more information about by clicking the relevant links.

Third Party Cookies
Third party cookies are those placed on your device by third party website domains. This includes social sharing, videos and other services we offer that are run by other companies. You can view information about what some of these sites do with your information here:
Facebook
AddThis
MyPeopleBiz
YouTube

You can disable those cookies in "3rd Party Cookies" section of our GDPR popup.

EMBEDDED CONTENT FROM OTHER WEBSITES

Articles on this website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behave in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

HOW TO MANAGE COOKIES

You may refuse or accept cookies at any time by adapting your browser settings. These links below explain how you can control cookies via your browser, although this turns cookies off on all websites and not just this one:

Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
Firefox: https://kb.iu.edu/d/ajfi

Alternatively, visit www.aboutcookies.org for detailed information on cookies and how to prevent these from being set.

This Cookie Policy is effective from 28th April 2020.

Job Applicant Data Policy

Key Definitions

Data processing

Personal data

Sensitive personal data

Privacy Notice

Fair Processing of Data

Fair processing principles

Lawful processing of personal data

Lawful processing of sensitive personal data

Lawful processing of information about criminal convictions

Consent to data processing

Automated decision making

Collection and Retention of Data

Collection of data

Retention of data

Data Security and Sharing

Data security

Data sharing

Staff Member Rights and Obligations

Accuracy of data

Applicant rights

Data subject access requests

Compliance with this Policy

The Company’s responsibility for compliance

Data security breaches

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