Privacy policy for the Swan Partners recruitment process
We at Swan Partners manage our recruitment process through our career site (the “Career Site”), and by using a related applicant tracking system.
Purpose
This privacy policy explains how Swan Partners uses personal data during recruitment, including when you visit our Career Site, apply for a role, are sourced or referred, or provide a reference.
At a glance
In summary, we use recruitment personal data to assess candidates, manage applications, communicate about roles, meet legal obligations and protect our rights.
- We collect contact details, application information, interview notes, references and relevant screening information.
- Where appropriate and lawful, we may collect equality monitoring, disability adjustment, right-to-work and criminal records information.
- We share data with recruitment and system providers, public authorities where required, and legal or corporate transaction parties where necessary.
- Unsuccessful applicant records are normally kept until April following 24 months from initial receipt, unless a lawful reason requires longer retention.
- You have data protection rights, including rights to access, correct, delete, restrict or object to processing, subject to legal conditions.
This privacy policy explains how we process your personal data if:
- you visit our Career Site as a visitor;
- you connect with us via our Career Site to create a profile and receive information about current or future vacancies;
- you apply for a position with us through our Career Site or a third-party service, such as a recruitment agency;
- we collect information about you from other parties, sites or services because we believe your profile may be relevant to current or future vacancies;
- we receive information about you from a direct or indirect referral because your profile may be relevant to current or future vacancies; or
- a candidate lists you as a reference.
This privacy policy also describes what rights you have when we process your personal data, and how you can exercise these rights.
In this privacy policy, “Candidate” means a person who connects with us, applies for a role, is sourced by us or is referred to us.
1. About processing of personal data
Personal data is information that can directly or indirectly identify a living person, such as a name, email address, telephone number or IP address. Processing personal data means doing anything with it, including collecting, creating, analysing, sharing, storing or deleting it.
There are laws and regulations on how organisations may process personal data, known as data protection laws. Different data protection laws apply to different types of use of personal data and in different parts of the world. The data protection laws that are relevant to our use of your personal data, as described in this privacy policy, include the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018. Where relevant, the EU General Data Protection Regulation (“EU GDPR”) may also apply.
Most obligations under data protection law apply to the data controller. The data controller decides why and how personal data is processed. A data processor processes personal data only on behalf of the data controller and in line with the data controller’s instructions.
Swan Partners is the data controller for the personal data processing described in this privacy policy.
2. What personal data do we process?
All individuals
Device information
If you visit our Career Site, we will collect information about your device, such as IP address, browser type and version, session behaviour, traffic source, screen resolution, preferred language, geographic location, operating system and device settings/usage.
Technical and statistical data
If you visit our Career Site, we will collect technical and statistical data about your use of the site, such as information about which URLs you visit, and your activity on the site.
Communications data
We will collect and store your communication with us, including the information you provide in the communication. This may include the content of emails, messages on social media, information you add to your account with us, surveys and, where introduced in future and notified to you in advance, interview recordings.
Contact details
Such as your name, email address, telephone number and physical address.
Candidates
Data from interviews, assessments and other information from the recruitment process
Such as notes from interviews with you, assessments and tests made, salary requirements.
Information in your application
Such as your CV, cover letter, work samples, references, letters of recommendation and education.
Information in your public profile
Information we collect about you from public sources related to your professional experience, such as LinkedIn or the website of your current employer.
Information provided by references
Information we receive from employees, partners or the people you have listed as references.
Special category, equality monitoring and recruitment screening data
Where relevant to recruitment, we may collect equality monitoring information, disability or reasonable adjustment information, right-to-work information and, where required for the role or by law, criminal records information. Equality monitoring information may include special category data, such as race or ethnic origin, sex, disability or other protected characteristics. We only collect this information where it is appropriate, proportionate and permitted by law.
3. Where do we receive your personal data from?
All individuals
From the Career Site
If you visit our Career Site, we collect technical and statistical information about how you use the Career Site, and information from your device.
All individuals
Directly from you
Most of the information we process about you is provided directly by you, for example when you apply for a position with us or connect with us. You can choose not to provide certain information, but some personal data is needed so that we can process your application or respond to your request.
References and Screening
From the person for whom you are a reference
If a candidate lists you as their reference, we collect your contact details, including name, title, organisation, email address and telephone number, so that we can contact you.
Candidates
From public sources
We may collect personal data about you from public sources, such as LinkedIn or the website of your current employer.
Candidates
From our references
We may receive information about you from employees or third parties, such as recruitment service providers, where they believe your profile may be relevant to current or future vacancies.
Candidates
From your references
If you provide us with references, we may collect information about you from them.
Candidates
Data we create ourselves or in cooperation with you
Information about your application and profile is usually created by us, or by us together with you, during recruitment. This may include interview notes, assessments and test results.
Candidates
From you or from screening providers
We may receive equality monitoring, disability adjustment, right-to-work and criminal records information directly from you and, where applicable, from recruitment, background checking or right-to-work verification providers.
4. For what purposes do we process your personal data?
The table below groups our recruitment processing purposes by theme so that it is easier to understand why we use personal data.
Theme
Purpose
Affected individuals
Categories of personal data
Legal and compliance
Protect and enforce our rights, interests and the interests of others, for example in connection with legal claims.
The individual(s) affected by the legal issue - this may include persons from all categories of individuals listed above.
All the categories of personal data listed above can be used for this purpose.
Sharing and administration
Share your personal data with other recipients, for the purposes mentioned in Section 5 below.
Varies depending on the purpose of the sharing, see Section 5 below.
All the categories of personal data listed above may be used for this purpose.
Career Site operation
Collect information about your use of the career site, using cookies and other tracking technologies, as described in our Cookie Policy.
Visitors.
Device information
Career Site operation
Maintain, develop, test, and otherwise ensure the security of the career site.
Visitors.
Device information; Technical and statistical data
Career Site operation
Analyse how the Career Site and its content are used, generate statistics and improve operational performance.
Visitors.
Device information; Technical and statistical data
Recruitment communications
Provide you with updates about vacancies with us.
Connecting Candidates
Contact details; Communications data.
Candidate assessment
Review profiles and applications sent to us. This also includes communicating with you about your application and profile.
Connecting Candidates; Applying Candidates
All the categories of personal data listed above may be used for this purpose.
Candidate assessment
Collect and evaluate your professional profile on our own initiative. This also includes communicating with you regarding your profile.
Sourced Candidates; Referred Candidates
All the categories of personal data listed above may be used for this purpose.
Recruitment communications
Contact you directly about specific, future vacancies with us.
Candidates.
All the categories of personal data listed above may be used for this purpose.
Interview recording
Record interviews if we introduce interview recording in future, tell you in advance and obtain any required consent.
Candidates.
Communications data.
Recruitment communications
Contact you to ask for your participation in surveys.
Candidates.
All the categories of personal data listed above may be used for this purpose.
Screening and equality monitoring
Monitor equality and diversity, consider reasonable adjustments, verify right to work and carry out role-related criminal records checks where required.
Candidates.
Special category data, equality monitoring data, disability or adjustment information, right-to-work information and criminal records information where relevant.
References
Contact you to ask you to provide information about a candidate and evaluate the information you provide.
References.
Contact details; Communications data.
5. Whom do we share your personal data with?
Our service providers
We share your personal data with our suppliers who provide services and functionality in our recruitment process. For example, this includes recruitment service providers and the supplier of our Career Site and related applicant tracking system.
Companies providing cookies on the Career Site
If you consent, cookies may be set by companies other than Swan Partners. Those companies will use the data collected by their cookies in accordance with their own privacy policies. You can find more information in our Cookie Policy.
Authorities and other public bodies
We will share your personal data with authorities and other public bodies when we have a legal obligation to do so.
Parties involved in legal proceedings
Where needed to protect or defend our rights, we may share your personal data with public authorities or other parties involved in a potential or existing legal proceeding, for example in connection with a discrimination claim.
Mergers, acquisitions and similar transactions
In connection with a potential merger, sale of company assets, financing, or acquisition of all or part of our business by another company, we may share your personal data with other parties involved in the process.
6. On what legal bases do we process your personal data?
We need a lawful basis to process your personal data. A lawful basis is a reason permitted under applicable data protection law.
For most recruitment processing described in this privacy policy, we rely on our legitimate interests in identifying, assessing and recruiting people with relevant skills and experience. We have assessed that this processing is necessary for those interests and that our interests are not overridden by your rights and freedoms.
You can contact us if you would like more information about this assessment. See Sections 9 and 10 below for contact details.
In some circumstances, we may process personal data only with your consent. For example, if we introduce interview recording in future, we will tell you in advance and obtain any required consent. See Section 9 below for more information about your right to withdraw consent.
We process special category data, including equality monitoring or disability adjustment information, only where permitted by applicable data protection law. This may include processing that is necessary for employment law obligations, equality of opportunity monitoring, assessing working capacity, making reasonable adjustments, or where you have provided explicit consent. We process criminal records information only where permitted by law and where it is relevant and proportionate to the role or recruitment process.
7. When do we transfer your personal data outside the UK or EEA, and how do we protect it?
Some information may be stored or processed outside the UK or EEA. Where this happens, we use appropriate safeguards to protect your personal data to the standard required by applicable data protection law. These safeguards may include:
- transferring personal data to a country or organisation recognised as providing an adequate level of protection under applicable data protection law;
- using the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or EU Standard Contractual Clauses where applicable;
- using approved binding corporate rules, codes of conduct or certification mechanisms where available; or
- putting in place any other safeguard permitted under applicable data protection law.
8. For how long do we keep your personal data?
All individuals
If we process your personal data for the purpose of being able to protect and enforce our rights, we will keep your personal data until the relevant legal issue has been fully and finally resolved.
Visitors
We keep your personal data for security purposes for 24 months. The retention periods for cookies are set out in our Cookie Policy. We keep your personal data to analyse the performance of the Career Site for as long as we keep personal data about you for other recruitment purposes.
Candidates
If you are only a Connecting Candidate, we keep your personal data for as long as you remain connected with us.
For other candidates, we keep your personal data while we assess whether you are suitable for the relevant vacancy or vacancies.
If you are unsuccessful in the initial recruitment process, we keep applicant personal data, including CVs, interview notes and associated recruitment correspondence and documentation, until April following 24 months from initial receipt. We may keep it for longer where required because of a legal hold, complaint, claim, audit, regulatory matter, data subject rights request or another lawful reason. After that point, the information will be securely deleted, destroyed or anonymised in line with the Swan Partners Data Retention Policy.
Where possible, equality monitoring information is used in anonymised or aggregated form. Disability adjustment, right-to-work and criminal records information will be retained only for as long as necessary for recruitment, employment law, legal obligation, safeguarding, audit, dispute management or another lawful purpose, and will be minimised, deleted or anonymised where feasible.
If you are hired, your recruitment records become part of your employment records and are kept for the duration of your employment plus a minimum of 6 years from your last day of contractual employment, in line with the Swan Partners Data Retention Policy and the Employee Privacy Notice.
References
We keep your personal data for as long as we keep the personal data of the Candidate for whom you acted as a reference.
9. What rights do you have, and how can you exercise them?
The table below summarises your main rights. Some rights apply only in certain circumstances.
Right
What it means
Right to be informed
You have the right to be informed about how we process your personal data, including if we plan to use it for a new purpose.
Right of access
You can ask whether we process personal data about you and request a copy of that personal data.
Right to rectification
You can ask us to correct inaccurate personal data or complete information that you consider incomplete.
Right to erasure
In some cases, you can ask us to delete personal data about you, for example where it is no longer needed for the purpose collected.
Right to restrict processing
You can ask us to restrict processing in certain circumstances, such as while we assess an objection or accuracy concern.
Right to data portability
Where the right applies, you can request certain personal data in a structured, commonly used and machine-readable format.
Right to object
You can object to processing where we rely on legitimate interests, based on your particular circumstances.
Right to withdraw consent
Where we rely on consent, you can withdraw it at any time, without affecting processing that took place before withdrawal.
Automated decision-making and profiling
You have rights where a decision is based solely on automated processing and has legal or similarly significant effects on you.
Right to complain
If you have concerns, you can complain to the Information Commissioner’s Office if you are based in the UK, or to your local data protection authority if based elsewhere.
If you want to exercise any of these rights, you can visit the Data & Privacy page on our Career Site, log in to your account where available, or contact us directly at careers@swan-partners.co.uk.
If you want to exercise any of the rights listed here, we suggest that you:
- Visit the Data & Privacy page on our Career Site;
- Log in to your account with us, where you can use the appropriate account settings; or
- Contact us directly at careers@swan-partners.co.uk.
10. Where can you turn with comments or questions?
If you want to get in touch with us to exercise your rights, or if you have any questions, comments or concerns about how we handle your personal data, you can reach us by sending an email to careers@swan-partners.co.uk.
11. Updates to this Privacy policy
We update this privacy policy when necessary, for example if we start processing personal data in a new way, if we want to make the information clearer, or if changes are needed to comply with applicable data protection laws.
We encourage you to regularly check this page for any changes. You can always check the top of this page to see when this privacy policy was last updated.