What is the purpose of this document?
Hassans Services Company Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being provided with a copy of this privacy notice because you are applying for work with us, Hassans International Law Firm Limited, or Line Group Limited (together ‘the Group’) (including 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 Gibraltar General Data Protection Regulation (Gib GDPR) and the Data Protection Act 2004.
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.
- The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, employment history, skills, experience, and qualifications,
- Any information you provide to us during an interview.
- Information about your current level of remuneration, including benefit entitlements.
- Information about your entitlement to work in Gibraltar.
- Any assessment or other test results
We may also collect, store and use the following types of more sensitive personal information:
- Information about your sex (gender), age, race and ethnicity, religion or beliefs, disability, sexual orientation, and gender reassignment status.
- Information about your health, including any medical condition, health, and sickness records.
- Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about candidates from the following sources:
- You, the candidate.
- Recruitment agencies
- Background check providers, from which we collect the following categories of data e.g. potential links to bribery, money laundering, politically exposed persons, (alleged) terrorism, corruption, fraud risk, miscellaneous risk both in the UK, Gibraltar and internationally, as well as directorships, disqualified directorships and/or non-executive directorships under the candidate’s name which may constitute a conflict of interest.
- Criminal Records self-declaration, Royal Gibraltar Police checks and/or, UK Disclosure and Barring Service in respect of criminal convictions, or other country relevant certificates of good conduct.
- Your named referees, from whom we collect the following categories of data: information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance.
How we will use information about you
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for any role you are being considered for (“the Role”).
- Carry out background and reference checks, where applicable (prior to making a decision to recruit).
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
- If you choose to join our talent pool, for the purposes of managing the talent pool
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 position.
We also need to process your personal information to decide whether to enter into a contract of employment or services as applicable with you.
Having received your CV and covering letter and/or your application form and the results of any test or assessment which you may have taken, we will then process that information to decide whether you meet the basic requirements to be shortlisted. 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 to decide whether to offer you a role. If we decide to offer you a role, we will then take up references and/or carry out a criminal record or other checks 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 references 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 information 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.
- Our aim is to be an inclusive organisation, committed to providing equal opportunities throughout employment. We will use information about your sex (gender), age, race, ethnicity, religion or beliefs, sexual orientation, and gender reassignment status, to ensure meaningful equal opportunities monitoring and reporting. You do not have to provide us with this information and if you do, we will only process it anonymously and it will not affect any decision by us on whether to recruit you or not.
Information about criminal convictions
We envisage that we will process information about criminal convictions prior to making the final decision to recruit.
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 may carry out a criminal record check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. Similarly, we may also process information about criminal convictions if you provide such information to us and we need to verify it. In either case you will be notified beforehand if this is the case.
We also have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
More details about the information we collect and hold, why we do so and how we use it and with whom it might be shared appears in Schedule 1 Part A (up to and including shortlisting stage) and Part B (additional information we collect before making final decision to recruit)
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?
Your information will be shared internally for the purposes of the recruitment process. This includes members of the HR Team, recruiting managers, interviewers, assessors and other staff involved in the recruitment process, and IT staff if access to the data is necessary for the performance of their roles.
We will only share your personal information with the following for the purposes of processing your application: Hassans International Law Firm Limited and Line Group Limited
We may also share your information externally with HR consultants and professional advisors for the purposes of the recruitment exercise only. When we do so they must only process this information according to our instructions and for no other purpose.
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 on our behalf 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 13 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. After this period, unless you have chosen to join the talent pool, we will securely destroy your personal information in accordance with applicable laws and regulations.
If you wish us to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, you can choose to join our talent pool via our recruitment portal. You will be asked periodically to renew whether you wish to remain in our talent pool. Should you fail to renew your interest when asked, we will securely destroy your personal information in accordance with applicable laws and regulations 13 months after you last indicated your desire for your information to be kept in the talent pool.
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. The periods for which your data will be held will be provided to you in a new employee privacy notice.
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 our Data Protection Officer by email at firstname.lastname@example.org .
Right to withdraw consent
If we have asked your consent to process any personal information relating to you in connection with the recruitment exercise, you have the right to withdraw your consent at any time. To withdraw your consent, please contact our Data Protection Officer by email at email@example.com . Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely
Data protection officer
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO by email at firstname.lastname@example.org. You have the right to make a complaint with the Gibraltar Regulatory Authority (GRA), Gibraltar’s supervisory authority for data protection issues.
About the information we collect and hold
Part A – Up to and including the shortlisting stage
|The information we collect||How we collect the information||Why we collect the information||How we use and may share the information|
|Your name and contact details (ie address, home and mobile phone numbers, email address) and other information provided to us in your curriculum vitae and covering letter||From you, when you provide us with a curriculum vitae, covering letter of fill out an application form.||Legitimate interest: to carry out a fair recruitment process Legitimate interest: to progress your application, arrange interviews and inform you of the outcome at all stages||To enable HR personnel to contact you to progress your application, arrange interviews and inform you of the outcome To inform the relevant manager or department of your application|
|Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests||From you, in the completed application form, curriculum vitae and interview notes (if relevant)||Legitimate interest: to carry out a fair recruitment process Legitimate interest: to make an informed decision to shortlist for interview and (if relevant) to recruit or to join our talent pool||To make an informed recruitment decision|
|Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs||From you, in a completed anonymised equal opportunities monitoring form||To comply with our legal obligations and for reasons of substantial public interest (equality of opportunity or treatment)||To comply with equal opportunities monitoring obligations|
|Details of any assessments or other test results||From your completed application form or curriculum vitae||Legitimate interest: to carry out a fair recruitment process to comply with our legal obligations to obtain regulatory references||To carry out a fair recruitment process To comply with legal/regulatory obligations Information shared with relevant managers, HR personnel and the referee|
Part B – Before making a final decision to recruit
|The information we collect||How we collect the information||Why we collect the information||How we use and may share the information|
|Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers||From your referees (details of whom you will have provided)||Legitimate interest: to make an informed decision to recruit To comply with our legal obligations Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice||To obtain the relevant reference about you To comply with legal/regulatory obligations Information shared with relevant managers and HR personnel|
|Information regarding your academic and professional qualifications||From you, from your education provider, from the relevant professional body||Legitimate interest: to verify the qualifications information provided by you||To make an informed recruitment decision|
|Information regarding your criminal record, in a criminal records certificate (CRC) or other similar certificate of good conduct as appropriate||From you and from the Disclosure and Barring Service (DBS), the Royal Gibraltar Police or other similar international authority.||To perform the employment contract To comply with our legal obligations [Legitimate interest: to verify the criminal records information provided by you For reasons of substantial public interest (employment rights preventing or detecting unlawful acts and protecting the public against dishonesty)||To make an informed recruitment decision To carry out statutory checks Information shared with DBS, RGP and other regulatory authorities as required|
|Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information||From you and, where necessary, the Royal Gibraltar Police||To enter into/perform the employment contract To comply with our legal obligations Legitimate interest: to maintain employment records To carry out obligations and exercise rights in employment law For reasons of substantial public interest (preventing or detecting unlawful acts)||To carry out right to work checks Information may be shared with the Royal Gibraltar Police or other local law enforcement authority as required.|
|Information relating to your health||From you and/or your medical practitioner||To enter into/perform the employment contract To comply with our legal obligations For the purposes of obligations and rights in employment and social security law||To make an informed recruitment decision|
If your application is unsuccessful at this stage, we may keep your information if you wish to join our talent pool. See section “how long will you use my information for?”