Privacy Notice for Candidates
Spencer Private Hospitals is committed to protecting the privacy and security of your personal data.
The purpose of this privacy notice is to let you know clearly how Spencer Private Hospitals collects and uses personal data about you for the purposes of the recruitment exercise that you are taking part in (whether as an employee, worker or contractor).
Spencer Private Hospitals Limited is a ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important that you read and understand this notice so that you are aware of how and why we are using your personal data.
Privacy Notice for Candidates
In connection with your application for work with us, we will collect, store, and use personal data about you that you have provided to us directly as part of the application process. This may include, for example, information in application forms, CVs or resumes and covering letters, or collected through interview or other forms of assessment including tests.
We may also collect personal data about you from the following sources:
- NAG, Discovery Park, Sandwich - recruitment agency
- Recruitment Solutions, Folkestone - recruitment agency
- HRGO, Dover, Canterbury, Ashford - recruitment agency
- Trapeze, Manston Green Industries - recruitment agency
- WE Solutions, London - recruitment agency
- Page Personnel, Maidstone - recruitment agency
- Sophie Bell, Canterbury - recruitment agency
- Disclosure and Barring Service in respect of criminal convictions.
- Your named referees
Personal data that we collect about you from third parties may include:
- recruitment information (including copies of right to work documentation, references and other information included in a cv or cover letter or as part of the application process)
- employment records (including job titles, working hours, training records, qualifications, professional memberships and employment history, including start and end dates with previous employers)
- information about your entitlement to work in the UK
We may collect, store and use the following "special categories" of more sensitive personal data about you:
- information about your race or ethnicity and religious beliefs.
- information about your health, including any medical condition, health and sickness records
- information about criminal convictions and offences
Your personal data will be stored in a range of different places, including on your application records, in HR management systems and on other IT systems (including email).
Spencer Private Hospitals has a legitimate interest in processing your personal data during the recruitment process and for keeping records of the process. Processing personal data about candidates allows Spencer Private Hospitals to manage the recruitment process, assess and confirm a candidate's suitability for employment or engagement and decide who to make an offer to. Spencer Private Hospitals may also need to process personal data about candidates to respond to and defend against legal claims.
Spencer Private Hospitals needs to process personal data about you to take steps at your request prior to entering into a contract with you. It may also need to process your personal data to enter into a contract with you.
In some cases, Spencer Private Hospitals needs to process personal data about you to ensure that it is complying with its legal obligations. For example, it is required to check a successful candidate's eligibility to work in the UK before employment starts.
Spencer Private Hospitals may process special categories of personal data, such as information about ethnic origin, religion or belief, for equal opportunity monitoring purposes. It may also collect information about whether candidates are disabled to make reasonable adjustments for candidates who have a disability. Spencer Private Hospitals processes such information to carry out its obligations and exercise specific rights in relation to employment.
For all roles, Spencer Private Hospitals is obliged to seek information about criminal convictions and offences. We will only collect this information where we are legally able to do so. Where Spencer Private Hospitals seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
Spencer Private Hospitals may also need to process personal data, special categories of personal data and information about criminal convictions and offences about candidates to respond to and defend against legal claims, where it is necessary to protect your interests (or someone else’s interest) and you are not capable of giving consent or where you have already made the information public.
If you do not provide information when requested, which is necessary for us to consider your application, we will not be able to process your application successfully.
Our recruitment processes are not based solely on automated decision-making.
Your personal data may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy, data protection team and IT staff if access to the data is necessary for the performance of their roles.
Spencer Private Hospitals will not share your personal data with third parties, unless your application for employment is successful and it makes you an offer of employment.
Spencer Private Hospitals will then share your personal data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
Spencer Private Hospitals will not transfer your personal data outside the European Economic Area.
Spencer Private Hospitals takes the security of your personal data seriously. We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, destroyed, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who need to access it in the proper performance of their roles for Spencer Private Hospitals. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. These measures are in accordance with applicable laws and regulations.
Where Spencer Private Hospitals engages third parties to process your personal data on its behalf, they are also obliged to implement appropriate technical and organisational measures to ensure the security of data.
If your application is successful, personal data gathered during the recruitment process will be transferred to our HR files and retained during your employment or engagement. This Privacy Notice will be superseded by the SPH Privacy Notice for Employees which will be provided to you with your contract of employment and will detail the duration of time we will continue to hold your personal data for.
If your application is unsuccessful, we will retain your personal data for a period of six months after we have communicated our decision to you. We retain your personal data for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal data in accordance with applicable laws and regulations.
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact the Risk and Information Manager, who can be contacted by emailing DataProtection@spencerhospitals.com or telephoning 01304 222682.
Under certain circumstances, by law you have the right to:
- request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
- request correction of incomplete or inaccurate personal data we hold about you
- request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have exercised your right to object to processing (see below)
- object to processing of your personal data where we are processing it for our legitimate interests (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
- request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it
- request the transfer of your personal data to another party where processing is carried out by automated means
If you would like to exercise any of these rights, please contact the Risk and Information Manager, who can be contacted by emailing DataProtection@spencerhospitals.com or telephoning 01304 222682
If you believe Spencer Private Hospitals has not complied with your data protection rights you can complain at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.
The ICO may be contacted at:
Post: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113 (local rate) or 01625 545745 (national rate)