1. PURPOSE
Innovative Solutions Group Limited, including its entities Innovative Trials Limited and Innovative Trials Inc, is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during the recruitment process, in accordance with Data Protection Legislation.
For the purpose of this policy, Data Protection Legislation includes all applicable data protection and privacy legislation in force from time to time in the UK including, but not limited to, the UK GDPR; the Data Protection Act 2018 (and regulations made thereunder); and the Privacy and Electronic Communications Regulations 2003 as amended; or any successor legislation, and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data (including, without limitation, the privacy of electronic communications).
It applies to everyone who creates a profile on our recruitment system and all candidates making a job application.
2. SCOPE
Innovative Solutions Group Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.
3. ABBREVIATIONS AND ACRONYMS
Consent means you freely provide a specific, informed, and unambiguous indication of your wishes through a written statement or clear affirmative action, inter alia, to being contacted by our marketing teams, or being asked to participate in a market research project which would be collected on our behalf by us or our third-party recruiters.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
4. REGULATORY REQUIREMENTS
UK Data Protection Act 2018
UK Privacy and Electronic Communications Regulations 2003
5. POLICY DETAILS
5.1 Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly, and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only, if necessary, for the purposes we have told you about.
- Kept securely.
5.2 The Kind Of Information We Hold About You
We will collect, store and use the following categories of personal information about you:
- Personal contact details such as name, title, address, telephone numbers, and personal email addresses.
- Recruitment information (including information included in a CV or cover letter or as part of the application process).
- Any information you provide to us during an interview.
We may also collect, store and use the following more sensitive types of personal information, which include:
- Information about your race or ethnicity, religious beliefs, sexual orientation.
- Information about your health, including any disability.
We may process sensitive personal information in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations or exercise rights in connection with recruitment.
- Where it is needed in the public interest, such as for equal opportunities monitoring.
5.3 How Is Your Personal Information Collected?
We collect personal information about candidates through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies, or other background check agencies.
5.4 Automated Decision-Making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. Recruitment processes are not based solely on automated decision-making. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless we have a lawful basis for doing so and we have notified you.
5.5 Data Sharing
5.5.1 Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, or where we have another legitimate interest in doing so. Third parties include but are not limited to our recruitment agency.
5.5.2 How Secure is my Information with Third-Party Service Providers and Other Entities in our Group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
5.6 Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. Additionally, we limit access to your personal information to individuals who have a business need to know. They will only process your personal information on our instruction and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
5.7 Data Retention
5.7.1 How Long Will You Use My Information For?
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements.
For successful candidates, the data will form part of their employment record and will be retained under our data privacy notice for employees, workers and contractors. Where you have been unsuccessful at the recruitment stage, your data will be held for no longer than 6 months.
5.8 Rights Of Access, Correction, Erasure And Restriction
5.8.1 Your Rights in Connection with Personal Information
Under certain circumstances, by law, you have the right to:
- Request access to your personal information (commonly known as a data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact a director in writing.
5.8.2 No Fee Usually Required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in these circumstances.
5.8.3 Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the DPO on [email protected]. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
5.9 Data Protection Officer (Dpo)
We have appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the [email protected]. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) with respect to data protection issues.
5.10 Changes To This Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact the DPO: [email protected].