A County Councils Network and Newton Research Programme
CANDIDATE PRIVACY NOTICE Welcome to Newton’s privacy notice which applies to all prospective Newton employees, workers and contractors. We may update it at any time. We have separate Privacy Notices for the following groups of people: - employees and contractors; - users of our website; - those agreeing to take part in our marketing activities/events; and - those whose data we may process on behalf of one or more of our clients. We need to collect and use certain information about you so that we can manage our relationship with you. Some information we collect, and use will be personal data. Newton Consulting Limited is a "data controller" and is responsible for your personal data (referred to as “Newton”, "we", "us" or "our" in this privacy notice). This means that we decide how we hold and use personal data about you. Newton respects your privacy. We think that it is important to be transparent about how we collect and use your personal data and are committed to protecting the privacy and security of the information we hold about you. This privacy notice provides more information about how we do this and provides you with certain information that must be provided under the retained EU law version of the General Data Protection Regulation ( UK GDPR ).
CONTACT
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below: Full name of legal entity: Newton Consulting Limited Email address: sarah.dasilva@newtonimpact.com Postal address: 2 Kingston Business Park, Kingston Bagpuize, Abingdon, Oxfordshire, OX13 5FE Telephone: 01865 601300
DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will 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;
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• kept only as long as necessary for the purposes we have told you about; and • kept securely.
WHAT PERSONAL DATA DO WE COLLECT?
We will collect, store and use a range of personal data about you. This includes the following: • the information you have provided to us in your curriculum vitae and covering letter; • the information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications; • test results for tests included as part of the recruitment process; • your video interview; • any information you provide to us during an interview or otherwise as part of our recruitment process. We may also collect, store and use the following types of more sensitive personal data: • information about your race or ethnicity, religious beliefs, sexual orientation and political opinions/affiliation/political party membership; • information about your health, including any medical condition, health and sickness records. Note that this expressly includes (but is not limited to) health data relating to Covid-19 testing; and • information about criminal convictions and offences.
HOW IS YOUR PERSONAL DATA COLLECTED?
We collect personal data about you in a variety of ways. For example, from: • you directly. For example, during interviews, meetings or assessments; • forms or other correspondence provided by you. For example, application forms, your CV, or other forms completed during the recruitment process; • samples provided by you (in the context of Covid-19 testing); and • your identity documents, such as your passport and/or driving licence. We may also collect personal data about you from third parties, such as: • your named referees; • recruitment agencies and other bodies, for example High Fliers Publications Limited who compile the Times Top 100 Graduate Employers; • the Disclosure and Barring Service in respect of criminal convictions;
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background check providers;
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credit reference agencies (as permitted by law); and
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• publicly accessible data from third parties, including LinkedIn and Facebook.
WHY DO WE NEED TO PROCESS YOUR PERSONAL DATA
We will need to collect, store and use personal data about you for a number of reasons: • to perform our obligations under your contract of employment (if you become employed by us) . For example, we need to process your personal data to pay you your salary and provide your benefits; • to ensure that we comply with our legal obligations . For example, we are required to check a candidate’s entitlement to work in the UK, to make reasonable adjustments (in certain circumstances), to comply with health and safety laws and (if you become employed by us), to deduct tax and to enable you to take holiday; • to pursue legitimate interests of our own, or those of third parties . When we do this, we always make sure that your fundamental interests and rights do not override those interests; and • because you have given your consent for us to do so . The examples given below do not form an exhaustive list of purposes for which your personal data will be processed, and we reserve the right to add to them at any time.
SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL DATA
The situations in which we will process your personal data are listed below: To comply with our legal obligations, including: • checking you are legally entitled to work in the UK; • dealing with legal disputes involving you, or other candidates, employees, workers and contractors; • ascertaining your fitness to work; • complying with health and safety obligations; • complying with our obligations to notify law enforcement about criminal activity or convictions; • complying with our obligation to make reasonable adjustments for employees, workers and contractors who have a disability; and • to prevent fraud. To pursue legitimate interests of our own, or those of third parties, including:
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• assessing your skills, qualifications, and suitability for the role; • deciding whether to enter into a contract of employment with you; • carrying out background and reference checks, where applicable; • communicating with you about the recruitment process; and • keeping records related to our hiring processes. In each of the above cases, the legitimate interest is to allow candidates to apply for a role at Newton and to ensure that we employ suitable candidates.
SPECIAL CATEGORIES OF PERSONAL DATA AND CRIMINAL CONVICTIONS
”Special categories” of personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data. We may process special categories of personal data in the following circumstances: • where we need to carry out our legal obligations ; • where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards; • where it is needed in relation to legal claim • where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent; or • where you have already made the information public. We will use your particularly sensitive personal data in the following ways: • we will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview ; and • we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We may use information relating to criminal convictions where relevant to the role you have applied /or where the law allows us to do so. For example, working in our public cluster may involve you being in contact with vulnerable adults and/or children. We therefore conduct enhanced DBS checks on all consultants before they start at Newton. We may also use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and
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you are not capable of giving your consent, or where you have already made the information public.
IF YOU FAIL TO PROVIDE PERSONAL DATA
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
WHO HAS ACCESS TO YOUR PERSONAL DATA?
Your information will be shared internally, including with HR, recruitment, finance and IT staff, in each case if and where access to the data is necessary for performance of their roles. We may also share your personal data externally with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. For example, we may share your personal data with third parties in order to: • manage, store and retain the data on our employee database, including our cloud based platform (currently HiBob); • administer our recruitment process. For example, we administer various stages of the application process using various recruitment agencies and third-party providers including (but not limited to) Oleeo plc, Launchpad Recruits Limited, Classmarker, Workable, Talenscio Limited, Amberjack Global Limited, HubSpot; • obtain pre-employment references from other employers or referees; • obtain employment background checks from third-party providers; • obtain necessary criminal records checks from the Disclosure and Barring Service; • obtain security clearance for you (if applicable); Where we share your personal data with third parties, we require that they respect the security of your data and treat it in accordance with the law. 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.
INTERNATIONAL TRANSFERS
Many of our external third parties are based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data to countries outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by virtue of an adequacy regulation under section 17A or adequacy decision under section 18(2) each of the DPA 2018; • Where we use certain service providers, we may use standard clauses approved by the Secretary of State under section 119A of the DPA 2018 which give personal data the same protection it has in the UK; and • where we use a service provider who is a member of a larger corporate group and this will involve the service provider transferring personal data outside the UK (but within their group of companies) the service provider may have binding corporate rules in place (checked and verified by us). Please contact us at graduates@newtonimpact.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
RECRUITMENT FAIRS AND UNIVERSITY EVENTS IN THE UNITED STATES OF AMERICA
When you meet us at a recruitment fair or university event in the United States and choose to share your details via our QR form, we process your personal data as described in this notice. Newton will use the details you provide (including your name, email address, school, major and graduation year) to contact you about opportunities at Newton and to consider you for current or future roles. We may store your details in our recruitment systems and share them with our recruitment team and service providers who support our recruitment activities. We process your personal data for the purposes of recruitment and talent management on the basis of our legitimate interests in identifying, assessing and engaging individuals who may be suitable for current or future roles within Newton.
HOW DO WE PROTECT YOUR PERSONAL DATA?
We have put in place measures to protect the security of your information. Details of these measures are available upon request. We have also put in place appropriate security measures to prevent your personal data from being accidentally lost, 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 have a business need to know. They will only process your personal data on our instructions, 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.
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Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After this period, we will securely destroy your personal data in accordance with applicable laws. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. We may retain your personal data on file on the basis that a further opportunity may arise in future and we may wish to consider you for that. We will only do this if you have given your explicit consent for us to retain your details for this purpose as part of the recruitment process.
WHAT ARE YOUR RIGHTS?
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 the personal data 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 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 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 data for direct marketing purposes; • 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; And • Request the transfer of your personal data to another party. If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to
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another party, please contact Recruitment in writing at 2 Kingston Business Park, Kingston Bagpuize, Abingdon, Oxfordshire, OX13 5FE, or by email at graduates@newtonimpact,com. You will not have to pay a fee to access your personal data (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 such circumstances. If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it. For citizens of the United States, depending on your state of residence and whether the relevant law applies to Newton, you may have additional rights.
AUTOMATED DECISION-MAKING
Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. 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. During the recruitment process, you may be subject to automated decision making in the initial screening of your application and in the marking of your test scores. Where you are subject to automated decision making, you will be expressly notified in advance. In these cases, you also have the right to request a reconsideration of the result of the automated decision making by submitting a reconsideration request to graduates@newtoneurope.com.
CHANGES TO THIS PRIVACY NOTICE
We keep our privacy policy under regular review and may update this privacy notice at any time. We may also notify you from time to time about the processing of your personal data. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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