Privacy Notice
Privacy Notice for Bridewell’s Recruitment & Hiring
The service for handling recruitments and simplifying the hiring process (the "Service") is powered by Teamtailor on behalf of Bridewell Consulting ("Controller" “we” “us” etc.). It is important that the persons using the Service ("Applicants” “you” “your” etc) feel safe with, and are informed about, how we handle their personal data in the recruitment process. We strive to maintain the highest possible standard regarding the protection of personal data. We process, manage, use, and protect User's Personal Data in accordance with this Privacy Policy ("Privacy Policy").
1. General
Bridewell are the controller in accordance with current data protection legislation and Teamtailor operates as a Processor on behalf of us. The Users’ personal data is processed with the purpose of managing and facilitating recruitment of employees to our business.
2. Personal Data we process and why
Bridewell is responsible for the processing of the personal data that the applicants provide as part of the recruitment and/or hiring process, or for the personal data that we collect from other sources.
When and how we collect personal data
We collect personal data about you from the following sources;
- Directly from you when you make an application through the Service or otherwise, adding personal data about themselves either personally or by using a third-party sources such as Facebook or LinkedIn; and
- Directly from you when you provide personal data in the chat (provided through the website that uses the Service) and such data is of relevance to your application;
We collect data from third parties, such as Facebook, LinkedIn and through other public sources. This is referred to as “Sourcing” and is manually performed by our employees or automatically in the Service.
In some cases, current Bridewell employees can make recommendations about potential applicants. Those employees will add personal data about potential applicants. In the cases where this is made, the potential applicant is considered a User in the context of this Privacy Policy and will be informed about the processing.
The types of personal data collected and processed
We collect the following categories of personal data to allow us to facilitate our recruitment and hiring processes:
- Personal Contact Details such as your name, e-mail address, postal address and telephone numbers.
- Pictures and videos.
- Publicly available information from Facebook and LinkedIn accounts.
- Responses to questions asked throughout the recruiting process.,
- Titles, education and other information that the User or others have provided through the Service.
Only data that is relevant for the recruitment process is collected and processed.
Purpose and lawfulness of processing
Depending on the processing activity, we rely on either Consent or Legitimate Interests to process your data for the purposes of recruitment and selection.
Personal data that is processed with the purpose of aggregated analysis or market research is always made unidentifiable. Such personal data cannot be used to identify a certain User. Thus, such data is not considered personal data.
Legitimate interests
Bridewell Consulting uses Legitimate Interests as the basis for processing personal data in the following circumstances:
- To allow users to make an application through the Service, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.
- To simplify and facilitate recruitment and selection.
We will also collect and process publicly available information about the User for use in recruitment.
The consent of the data subject
The User provides consents that personal data is collected through the Service, can be processed in the following circumstances;
- To be retained in the event of an unsuccessful application for future vacancies or job opportunities.
The User consents to the personal data being collected in accordance with the above and it will be processed according to the below sections ‘Storage’ and ‘Transfers’ and ‘How long we keep personal data’.
The User has the right to withdraw his or her consent at any time, by contacting Controller using the contact details listed under Section 9 of this Privacy Notice.
International Transfers
The personal data collected through the Service is stored and processed inside the EU/EEA, such third countries that are considered by the United Kingdom to have an adequate level of protection, or to other suppliers where adequate safeguards are in place to protect the rights of the data subjects whose data is transferred.
How long we keep personal data
Bridewell will only process personal data for as long as necessary or where we have a legitimate business reason for keeping it and in line with our Retention Schedule.
For successful candidates, your personal data will be retained for 6 years after the termination of your employment.
For unsuccessful candidates, your personal data will be retained for 12 months from your last interview. You will prompted to provide consent for your data to be held for a further 12 month period for future vacancies or job opportunities. This consent can be withdrawn at any time by contacting the Controller.
3. Your rights in relation to your data
You have a certain rights regarding the processing of your personal data, your rights are outlined below:
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Right to be informed: you have the right to be provided with information on how you personal data is processed, like through this Privacy Notice.
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Right to Access: you have right to request information about the personal data that is processed by us. Users have the right to a copy of the personal data being processed which belongs to them without any charge. Further may incur a charge of a reasonable fee on the basis of the administrative costs.
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Right to Rectification: you have a right to rectification of any inaccurate or incomplete personal data we hold about you.
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Right to Erasure: you can request we delete or stop processing or collecting your data.
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Right to Object: you have the right to object to processing based on legitimate interest such as us retaining your personal data for future recruitment purposes. You also have the right to withdraw any consent to processing that you have given.. Using this right may mean that the you cannot apply for a specific job or otherwise use the Service.
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Right to Data Portability: You have, under certain circumstances, a right to data portability, which means a right to get the personal data and transfer these to another controller as long as this does not negatively affect the rights and freedoms of other individuals.
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Right to not be subject to automated decision making: You have the right to not be subject to automated decision making and can either object to the processing or request that there is human involvement in any decisions being made. At this time, Bridewell do not carry out automated decision making as part of our Recruitment & Selection processes. If this changes, we will notify you by updating this Privacy Notice.
- Right to Lodge a Complaint: you have the right to lodge a complaint to the Data Protection Regulator, which for us in the UK is the Information Commissioners Office (ICO), regarding the processing of personal data relating to you.
Please find the ICO’s contact details below:
Postal Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Email: casework@ico.org.uk
Live Chat: https://ico.org.uk/global/contact-us/live-chat
Online Form: https://ico.org.uk/global/contact-us/email/
Telephone: 0303 123 1113
4. Security
We prioritise the personal integrity and therefore work actively so that the your personal data is processed with utmost care. We take the measures that can be reasonably expected to the make sure that the personal data of you and others are processed safely and in accordance to this Privacy Notice and applicable Data Protection Legislation.
However, transfers of information over the internet and mobile networks can never occur without any risk, so all transfers are made on the own risk of the person transferring the data. It is important that you take responsibility to ensure that their data is protected. It is your responsibility to ensure that you keep your login information secret.
5. Transfers of personal data to third parties
We will not sell or otherwise transfer your personal data to third parties.
We may transfer your Personal Data to;
- our contractors and sub-contractors, acting as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service;
- authorities or legal advisors in cases where criminal or improper behaviour is suspected; and
- authorities or legal advisors if required by us according to law or regulation.
We will only transfer your personal data to third parties that we have confidence in. We carefully choose partners to ensure that the your personal data is processed in accordance to current applicable Data Protection Legislation. We cooperate with the following categories of processors of personal data:
- Teamtailor, who supplies the Service, server and hosting companies;
- LinkedIn;
- e-mail reference companies;
- video processing companies;
- information-sourcing companies;
- analytical service companies; and
- other companies with regards to suppling the Service.
6. Aggregated data (non-identifiable personal data)
We may share aggregated data to third parties. The aggregated data has in such instances been compiled from information that has been collected through the Service and can, for example, consist of statistics of internet traffic or the geological location for the use of the Service. The aggregated data does not contain any information that can be used to identify individual persons and is thus not personal data.
7. Cookies
When Users use the Service, information about the usage may be stored as cookies. Cookies are passive text files that are stored in the internet browser on the User’s device, such as computer, mobile phone or tablet, when using the Service. We use cookies to improve the User’s usage of the Service and to gather information about, for example, statistics about the usage of the Service. This is done to secure, maintain and improve the Service. The information that is collected through the cookies can in some instances be personal data and is, in such instances, regulated by our Cookie Policy.
You can at any time disable the use of cookies by changing the local settings in their devices. Disabling of cookies can affect the experience of the Service, for example disabling some functions in the Service.
8. Changes to this Privacy Notice
From time to time, we will make changes or additions to this Privacy Notice. The latest version of the Privacy Notice will always be available through the Service.
For any significant changes, we will make this clear through the service and by other means of communication such as email, so that you are able to review the changes and make an informed decision as to whether you want to exercise any of your rights in relation to the processing of personal data.
Last updated: December 2021
9. Contact
For questions or further information about our handling of personal data, please contact us via th contact details below:
Email: bc@bridewellconsulting.com
Post: Data Protection Officer, Bridewell Consulting Ltd, 40 Caversham Road, Reading, RG1 7EB.
Telephone: +44 (0) 1189 255 084
For questions regarding your application or the recruitment process, please contact:
hannah.roome@bridewellconsulting.com
