Privacy Notice – Candidates
Contents:
What is the purpose of this document?
Data protection principles
The kind of information we hold about you
How your personal information is collected
How we use information about you
How we use more sensitive personal information
Information about criminal convictions or offences
If you fail to provide personal information
Data sharing
Change of purpose
Data security
Data retention
Your rights in connection with personal information
Contacting us about your information
Complaints
What is the purpose of this document?
Ohme Global Holdings Limited, and its subsidiary undertakings which include Ohme Operations UK Limited, Ohme Operations Ireland Limited, Ohme Australia Pty Limited and other subsidiary undertakings from time to time, (“Ohme”) is committed to protecting the privacy and security of your personal information in accordance with the UK General Data Protection Regulation, the EU General Data Protection Regulation and other applicable privacy laws.
This privacy notice describes how we collect and use personal information about you during recruitment activity, in accordance with relevant data protection legislation. You are being presented with this privacy notice because you are applying for work with us (whether as an employee or contractor). It makes you aware of how and why your personal data will be used and for how long it will usually be retained.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Ohme is a “data controller” which means that we are responsible for deciding how we hold and use personal information about you. We are required by law to notify you of the information contained in this privacy notice.
This notice applies to individuals who interact with Ohme as a result of any recruitment activity. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice from time to time.
Data protection principles
We will comply with applicable data protection laws. In particular, we will take steps to ensure that your data will be:
- Processed 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, where required, 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
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection. 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 (CV)/resume and covering letter which may include name, title, address, telephone number, personal email address or other contact information, information about your current and previous employment, photographs
- The information you have provided on your application form, including name, title, address, telephone number, personal email address or other contact information, education history, work experience, work permit, visa or other applicable authorisation to work status, and eligibility to work in the jurisdiction in which the position(s) you have applied are located
- Any other information you provide to us during an interview or otherwise in connection with your application
- If your application is successful, prior to your starting work we will collect certain pre-onboarding information from you through our HR system which may include passport number, National Insurance / Social Security number, home address, personal email address, personal mobile number, bank details, emergency contact details, preferred pronouns, date of birth, nationality, gender, ethnicity, and allergies
We may also collect, store and use the following types of more sensitive personal information:
- Information about you race or ethnicity, religious or philosophical beliefs, sexual orientation, gender identity, and political opinions
- Information about your health, including any medical condition, health and sickness records, disabilities, neurodiversity etc.
- where relevant to your role and permitted in accordance with applicable law, information about criminal convictions or offences
How your personal information is collected
We typically collect personal information about candidates through the following sources:
- You, the candidate
- Any third party recruitment platform we utilise
- Any recruitment agency that referred you to us, from which we collect the following categories of data: name, address, email address, telephone number, CV/resume
- our background check provider from which we collect the following categories of data: name, address, email address, educational information, information about previous and current roles held, credit report, electoral roll report, media search, credit report, right to work verification, identity verification, professional references where required, membership information and criminal record checks
- Disclosure and Barring Service (DBS), or equivalent in relevant jurisdiction, in respect of criminal convictions
- If your application is successful, information you input in response to pre on-boarding questions delivered through our HR platform
- Your named referees
How we use information about you
Ohme will process your personal information for the purposes of administrating the application process. This includes reviewing your personal information to assess your skills, qualifications and your suitability for our career opportunities, as well as to take measures to verify that the information you have provided is true and accurate, including by means of background and reference checks where permitted by applicable law. We will only use your personal information when the law allows us to, which will normally be:
- Where we need to in order to consider your CV/resume or application and throughout your participation in any recruitment process with Ohme
- Where we need to comply with a legal obligation
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
How we use more sensitive personal information
We will use your more sensitive personal information to consider whether we need to provide appropriate adjustments during the recruitment process.
Information about criminal convictions or offences
In certain cases we will process information about criminal convictions or offences. We will collect information about your criminal convictions or offences 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 or offences 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.
If you fail to provide personal information
We require your personal data described in this notice to allow us to run the recruitment process, including making appropriate adjustments, and to comply with our legal obligations.
If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations and/or we may not be able to continue with the recruitment process.
Data sharing
We will only share your personal information with Ohme group companies and the following third parties for the purposes of processing your application:
- the third party recruitment platform we use: In order to process your application for a vacant role
- third party building access systems and our office building management/security: We do this for security and health and safety reasons
- the third party we used to carry out background checks
- the third party HR platform we use for pre-onboarding information checks
- DBS or equivalent in relevant jurisdiction: for criminal conviction checks.
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.
Change of purpose
We will only use your personal information for the purposes for which we collect it, unless we reasonably consider that we need to use if for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so, which may involve us seeking your consent to such use of your personal information.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Data security
We have put in place measures designed to protect the security of your information, whether it is physically or virtually held by Ohme, including use of username and password security and secured servers with limited access control to persons with appropriate clearance.
We have put in place appropriate security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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
We will only retain your personal information 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. We will not retain candidates’ personal data for longer than 12 months without seeking their consent (for example, if they would like to remain on our database in case new positions become available).
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information. 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.
- Withdraw your consent to our processing of your personal data at any time (to the extent that the legal basis of that processing is your consent).
Contacting us about your information
If you wish to exercise any of the rights set out above, please contact [email protected] in writing.
You can also write to Ohme at the following address: Wellington House, 5th Floor, 125-130 Strand, London WC2R 0AP.
Ohme Operations UK Limited is registered with the Information Commissioner’s Office (ICO) as a data controller for the personal data that it processes under registration number ZA747612.
Complaints
If you believe Ohme has not complied with its data protection obligations, please contact [email protected] in the first instance.
If your complaint is not properly handled, you may also complain to the Information Commissioner’s Office.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Last Updated: 20 February 2024