Candidate Privacy Notice (UK & EU)
What is the purpose of this document?
Intouch Games Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR)
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.
- Any information you provide to us during an interview
- Details and results of any technical tests completed by you as part of the recruitment process
- Results of any psychometric assessments completed as part of the recruitment process
- Information provided to us for the purpose of reclaiming travel expenses (this can include a proof of identification for international applicants)
We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about criminal convictions and offences (we have a regulatory requirement to process this type of data for position requiring a certain level of access to our systems and to our financial data.)
- Information about your health and disabilities (we use this data to ensure that we provide all the necessary adjustments you might require during the interview process)
How is your personal information collected?
We collect personal information about candidates from the following sources:
- You, the candidate.
- GBG Know Your People background check provider, in respect of criminal convictions
- Your named referees, from whom we collect information about previous employment and post suitability
- The following data from third parties is from a publicly accessible source such as Linked In – employment history, skills, qualifications, recommendations, endorsements
How we will use information about
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 a 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 any pre requisite test results 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 and any test conducted a part of the interview process to decide whether to offer you the role. If we decide to offer you the role we will then take up references and carry out a criminal record check (where we have defined it is a requirement of the role) 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 criminal record 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.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
- We will use any information you provide 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.
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 entitled 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 will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. We will use information about criminal convictions and offences in the following ways:
- To inform employment decisions for those in positions considered to require a high degree of trust and integrity, specifically roles considered to be:
- Be managerial in nature
- Have access to restricted personnel data
- Have IT administrator access privileges
- Be involved in financial or accounting function
- Have unrestricted access to Intouch Games, or Ruskin properties premises and/or potentially vulnerable tenants
In this situation a criminal record check is a necessary, proportionate and appropriate measure to protect the security interests of the company, because the employee is in a position of trust. A Criminal record check may also be required to carry out our security obligations to the Gambling Commission.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We do not share your personal information any third parties.
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.
How long will you use my information for?
We will retain your personal information for a period of 18 months after we have communicated to you our decision about whether to appoint you to a role. 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.
- Should you be unsuitable for the role and apply for a further similar role within this time frame, we may refer to your data to make a decision about whether to continue with your application in order that we do not spend business resources undertaking unnecessary recruitment processing of candidates.
After this period, we will securely destroy your personal information in accordance with our data retention policy and our secure destruction policy.
If your application forms part of a resident labour market test (RLMT) for Tier 2 Visa sponsorship for a migrant worker, we are required by law to retain details of your application, including your CV and any interview notes or test results. These will be retained for a period of 12 months after the termination of the relevant migrant worker’s sponsorship.
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 Recruitment Team in writing.
Please note that if you would like to exercise any of the above rights, we will have to conduct certain prior checks including verifying your identity.
The Data Protection Officer is responsible for overseeing compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer. 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.