Tomorrow's Guides Recruitment Privacy Notice

1. Objective

The objective of this document is to provide job applicants with information about how their personal data will be used.

2. Scope

This notice applies to all external job applicants.

3. Principles

As part of recruitment processes, Tomorrow's Guides Limited ("TG") collects and processes personal data relating to job applicants. The business is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

3.1 What information does the business collect about you?

TG collects and processes a range of information during recruitment processes including:

  • your name, address and contact details, including email address and telephone number;
  • details of your qualifications, skills, experience and employment history;
  • information about your current level of remuneration, including benefit entitlements;
  • whether or not you have a disability for which the business needs to make reasonable adjustments during the recruitment process;
  • information about criminal convictions and offences;
  • information about your entitlement to work in the UK; and
  • equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief, as appropriate.

3.2 How is information collected?

TG collects job applicant information in a variety of ways. For example, data might be contained in application forms, CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

TG may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers, and information from criminal records checks. TG will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

3.3 Where is information stored?

Personal data will be stored in a range of different places, including our local network, in HR management systems and on other IT systems, including email.

3.4 Why does the business process personal data?

The business needs to process personal data for various reasons including taking necessary steps to contact you and, if applicable, prior to entering into a contract with you. It may also need to process your personal data to enter into a contract with you.

In some cases, TG needs to process personal data to ensure that it is complying with its legal obligations. For example, the business is required to check a successful applicant's eligibility to work in the UK before employment starts.

The business has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing personal data from job applicants allows TG to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. The business may also need to process personal data from job applicants to respond to and defend against complaints or claims.

In addition, TG may process special category personal information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability in order to carry out its obligations and exercise specific rights in relation to employment practices.

Where the business processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief as part of its recruitment practices, this is processed for equal opportunities monitoring purposes.

In some cases, it may be necessary to seek information about criminal convictions and offences. Where the business seeks this information, it does so because it is in our legitimate interests to do so to safeguard our clients. Accordingly, it may be necessary to verify whether you have a conviction which makes you unsuitable for a particular role with TG.

We consider that TG meets two of the further conditions required to process criminal convictions data, namely that the processing is necessary to protect the public against dishonesty and to prevent and detect unlawful acts.

If your application is unsuccessful, TG may keep your personal data on file in case there are future employment opportunities for which you may be suited.

3.5 Who has access to your data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR team, interviewers involved in the recruitment process, managers in the business area with a vacancy, and IT staff if access to the personal data is necessary for the performance of their roles.

Your personal data will be shared with our third-party data processors for the purpose of storage of your personal data, automating our recruitment processes, sending emails, [parsing CVs], sending internal communications and internal task management.

Apart from as set out above, the business will not share your personal data with third parties unless your application for employment is successful and it makes you an offer of employment. Where an offer is accepted, TG will share your personal data with third parties where there is a legitimate reason to do so including in order to obtain offer letters/contracts from our HR Consultant, to obtain pre-employment references from other employers and obtain employment background checks from third-party providers and/or necessary criminal records checks from the Disclosure and Barring Service.

We will not send your personal data outside the UK, except for:

  • personal data stored on SeeMeHired which is used to help manage our recruitment processes and is hosted in Ireland;
  • personal data stored in Trello which is used for task management and hosted in the US;
  • and transfer of your personal data to our parent company 'A Place For Mom, Inc.'

This transferred data is protected by appropriate safeguards, namely standard contractual clauses.

If you become an employee of TG, details of transfers of your personal data outside the UK will be set out in the TG Employee Data Protection Policy.

3.6 How does the business protect your data?

TG naturally takes the security of your personal data seriously. The business has internal policies and controls in place to try to ensure, as far as practicable, that your personal data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. Relevant policies are available on request.

3.7 How long is data held?

If your application for employment is unsuccessful, TG will hold your personal data on file for 2 years after the end of the relevant recruitment process. At the end of that period your personal data is deleted or destroyed. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment, in which case, retention periods will be covered by a separate privacy notice.

3.8 Your rights

As a data subject, you have a number of rights including:

  • obtaining a copy or access to your personal data on request;
  • requiring the business to change incorrect or incomplete personal data;
  • requesting that data be deleted or processing of your personal data be ceased, for example where the personal data is no longer necessary for the purposes of processing;
  • objecting to the processing of your personal data where the business is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights or have any questions or concerns, please contact the HR Department. You also have the option to address any concerns relating to your data protection rights directly with the Information Commissioner.

3.9 What if you do not provide personal data?

You are under no statutory or contractual obligation to provide personal data to the business during the recruitment process. However, if you do not provide the information, TG may not be able to process your application properly or at all.

3.10 Automated decision-making

Recruitment decisions are not based solely on automated decision-making.

4. Review

TG will review the effectiveness of this notice annually and in line with changes in legislation and best practice.