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Privacy - Candidate

What is the purpose of this document?
Huws Gray Limited (“Huws Gray”) (company number 2506633) is a trading subsidiary of Holyhead Topco Limited (company number 11275148). Holyhead Topco Limited  is made up of different legal entities, the Holyhead Topco Group details of which can be found here www.huwsgray.co.uk/shop/privacy
This privacy notice is issued on behalf of the Holyhead Topco Group so when we mention "Huws Gray" in this privacy notice, we are referring to the relevant company in the Holyhead Topco Group responsible for processing your data. We will let you know which entity will be the controller of your data whenever we collect any personal data from you when dealing with one of the companies within the Holyhead Topco Group. The Holyhead Topco Group respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data as a recruitment applicant and tell you about your privacy rights and how the law protects you.
It applies to all recruitment applicants. A copy of this notice is available on the Huws Gray website and may be updated by us from time to time.

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.
•    Kept only as long as necessary for the purposes we have told you about.
•    Kept securely.


The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
•    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, hobbies and interests.
•    Any information you provide to us during an interview.

We may also collect, store and use the following "special categories" of more sensitive personal information:
•    Disclosures about criminal convictions and offences.


How is your personal information collected?
We collect personal information about candidates from the following sources:
•    You, the candidate.
•    Your named referees, from whom we collect the following categories of data: confirming work history & performance


How we will use information about you
We will use the personal information we collect about you to:
•    Assess your skills, qualifications, and suitability for the role.
•    Carry out background and reference checks, where applicable.
•    Communicate with you about the recruitment process.
•    Keep records related to our hiring processes.
•    Comply with legal or regulatory requirements.


It is in our legitimate interests to decide whether to appoint you to role since it would be beneficial to our business to appoint someone to that role.
We also need to process your personal information to decide whether to enter into a contract of employment with you.
Having received your CV and covering letter and/or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and ask for criminal offence disclosures before confirming your appointment.


If you fail to provide personal information
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 a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

Information about criminal convictions
We envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitle to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.


Data sharing
Will you share my personal information with third parties?
We do not share your application details with any third party.

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. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information 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.

Data retention
How long will you use my information for?
We will retain your personal information for a period of 6 months after we have communicated to you our decision about whether to appoint you to work. We retain your personal information 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 information in accordance with our data retention policy.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

Rights of access, correction, erasure, and restriction
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 the Compliance Officer in writing.
Right to withdraw consent


When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact dataprotection@huwsgray.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

Compliance officer
We have appointed a compliance 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 compliance officer on dataprotection@huwsgray.co.uk. You 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.

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