Recruitment and Appointment Privacy Policy

July 2015

  1. Summary

This Recruitment and Appointment Privacy Policy (this ‘policy’) describes the types of personal information that the College of Policing (‘the College’) and our partners (referred to as either our ‘policing partners’ or ‘the police service’, and collectively as ‘we’ or ‘us’) may collect; how we may use the information; with whom we may share it; and the choices that you can make regarding our use of the information.

The use and disclosure of personal data is governed in the United Kingdom by theDataProtection Act 1998[1](‘the Act’). The Chief Executive Officer of the College isregisteredwith theInformation Commissioner[2] (registration no: Z3458257)as a ‘DataController’[3] for the purposes of the Act. He is, therefore, obligedto ensure that the College handlesall personal data in accordance with the Act.

Wetake our responsibility very seriously and applies great care to ensure that all personaldata is handled appropriately in order to secure and maintain individuals’ trust and confidence inthe College.

The personal identifiable information (‘personal data’) that you provide to the College as an applicant for a position with us or our policing partners will be used for recruitment, employment, appointment and related purposes. Your personal data will be protected in accordance with this policy and applicable law. Described in more detail below, personal data includes any identifiable information about you that you or anyone else may provide (on your or the College’s behalf) in the context of an application for a position with us or our policing partners.

For information on the College’s general privacy policy or cookie policy, please go to:

  • Fair Processing Notice[4]
  • Cookie Policy[5]
  1. Consent

By submitting your personal information, you confirm and agree that you have read and understood this policy. You also agree that the College and our policing partners may process your candidate, employment or appointment data according to the purposes set out in this policy.

This policy is not contractual in nature and so does not form any part of any contract of employment, appointment or any offer.

  1. Collection of personal data

We use various methods to collect personal data in order to evaluate the suitability of a person’s appointment to, or (continued) employment, with the College or a police force.

Such methods may include:

  • the processing of any applications you make to the College or to our policing partners, whether made online, by email or by paper submission
  • the processing of any information supplied to us via third parties including (but not limited to) referees that you have nominated. This policy will govern all such additional candidate data.

Candidates should be aware that providing false information during any part of the application process may constitute a criminal offence. It is very likely to lead to the rejection of your application, the retraction of any security clearance status or termination of any subsequent employment.

  1. Purposes for processing personal data

The College and our policing partners may process your personal data for legitimate human resources purposes as set out in this policy. These purposes include but are not necessarily limited to:

  • identifying and/or evaluating candidates for College or police force positions
  • making a decision about whether or not an individual should be hired or appointed including the conducting of security clearance and vetting checks, which may or may not be conducted by other government police or security agencies
  • the purposes of equal opportunities monitoring
  • maintaining appropriate record-keeping related to hiring practices
  • any additional purposes set out in the applications or submissions you complete.

Candidates, employees and officers should also note the following additional purposes. For processing personal data.

4.1Research and Statistics

The College may, periodically, collect candidate, employee, and officer feedback and opinions (e.g., from surveys) for business purposes, such as improving processes. We may also process information gathered about you to help analyse our employment and appointment processes, including (but not limited to) advertising, hiring and appointment, training, promotion, attrition and outcomes.

Such analysis may be conducted by the College or external police-related organisations and academic partners, and may lead to the publication or official reporting of any results of the research. Such publications will, however, include only accumulated statistical data and will not, under any circumstances, include any personal data about you unless specifically stated and your consent has been obtained.

You are free to choose whether or not to respond to any surveys sent to you by the College and you will not suffer reprisals for your decision not to partake in a survey.

4.2Transparency Requirements

Candidates, employees and officers should be aware that the College and the police service have provided a firm commitment to the public, our members and the UK government that we will operate transparently where it is appropriate to do so. We are also subject to the provisions of the Freedom of Information Act 2000 that require us to publish or otherwise disclose information that is in the public interest. Such information may include the actions, activities and other information processed by us about you in your official capacity while you are employed with, or appointed by, us. This commitment and requirement do not affect your ‘privacy’ rights. (See Article 8 of the European Convention on Human Rights and Principle 6 of the Data Protection Act 1998.)

4.3Disapproved Register

Candidates, employees and officers should also be aware that any officer who is found guilty of any offence, is subject to gross misconduct proceedings, or resigns or leaves the College or police service before any action/proceedings take place, may be added to the Police Service Disapproved Register. This commitment and requirement do not affect your ‘privacy’ rights. (See Article 8 of the European Convention on Human Rights and Principle 6 of the Data Protection Act 1998.)

  1. Types of personal data

The types of personal data we may obtain include:

  • work history and experience
  • education, including professional qualifications and memberships
  • pay, benefits and compensation history
  • employer feedback, references and any other details of past employers or other people you have nominated for us to contact
  • online questionnaire results
  • contact information (eg, your name, postal or email address, and phone or fax number as applicable)
  • your previous addresses and any previous names you have used
  • any additional information you provide (eg, a cover letter)
  • administrative and national identifying numbers (eg, passport, driving licence, National Insurance numbers
  • criminal history, including commission or alleged commission of any criminal offence worldwide
  • social media account information (but not passwords)
  • banking and finance details/history (but not PINs, passwords or any other security data)
  • family and associates information
  • other sensitive information (e.g., your image, physical appearance details, sex, ethnic origin, caring responsibilities, languages spoken/preferences,ethnicity,religion, political preferences/activities, trade union membership, age, date of birth, sexual orientation, health information and gender).

The College and the police service reserve the right to process the above information for the purposes of national security, the prevention and detection of crime, and the apprehension of offenders. We will endeavour to notify you of any such processing, but no prior notification will be givenif do so may jeopardise these purposes.

  1. Security and confidentiality

TheCollege takes the security of all personal data under our control very seriously. We will complywith the relevant parts of the Act relating to security, and seek to comply with theAssociation of Chief Police Officers’ Community Security Policyand relevant parts of theISO27001 Information Security Standard.

We will ensure that appropriate policy, training, technical and procedural measures are in place,including audit and inspection, to protect our manual and electronic information systems fromdata loss and misuse.We will only permit access to them when there is a legitimate reason for doing so,and then under strict guidelines as to the use that may be made of any personal data contained withinthem. These procedures are continuously managed and enhanced to ensure up-to-date security.

Please be aware that emails you send us from an unaccredited email address, and those that we may send to your unaccredited email address, are not secure because email messages can be intercepted. We will hold your information securely, but there can be no guarantee of privacy with such email communication. Therefore, we advise you to not email any information which, if disclosed to unrelated third parties, would be likely to cause you damage or distress. You should perform your own virus checks on any emails you receive.

We suggest that you encrypt your email and any attachments. You should also password protect any attachment and notify us of the password by separate communication.

  1. Retention periods

We will hold the information you submit in accordance with this data privacy statement for a period of one year for unsuccessful candidates, and for the duration of your employment/appointment plus six years for successful candidates. All data will be deleted after the appropriate period so you will need to resubmit this information should you wish to apply again.

You are encouraged to ensure that the candidate information you provide to the College is kept up to date, and to notify us of any information which is inaccurate or out of date so we can make the necessary amendments.

  1. Disclosure to third parties and international transfers

It may occasionally be necessary to disclose some personal data to a supplier or a contractor organisation (supplying services on the College’s behalf)if they require the use or creation of personal information about candidates, employees or officers. Such processing will be subject to strict contractual agreements which will require any data processor or third party data controller to abide by the requirements of the College’sprivacy and security policies.

It may also be necessary to disclose personal information in order to protect the legal interests and other rights and requirements of the College, for example, employment tribunal proceedings.

It may be necessary to utilise the services of international suppliers, and this may necessitate the processing of your application, employment or appointment data. We will, however, do this only for the purposes described in this policy. When we transfer your personal data to other countries, we will take steps to ensure the same level of protection for that personal data as is set out in this policy unless otherwise required by applicable laws.

It may be necessary to transfer some or all of your candidate, employment or appointment data to other countries, where it is required for the purposes of national security, prevention and detection of crime, or the apprehension or prosecution of offenders. Whilst we will endeavour to notify you of such processing, there may be occasions that such notifications will act in contrary to these purposes, which will necessitate the need to process this information without notification.

  1. Rights

Individuals have various rights enshrined in the Act.Candidates, officers and employees requiring further information should refer to the College’s Fair Processing Notice.[6]

  1. Changes to this policy

The College may need to modify this policy, for example, to comply with changes in business operations or laws and regulations. We will post all changes to this policy on our Intranet and Internet sites.

  1. Contact us

If you have any concerns about howwe handleyour personal data, please contactour Data Protection Officer:

Email:​

Mail:Data Protection Officer

Corporate Governance Unit
College of Policing
10th Floor Riverside House

2a Southwark Bridge Road

London

SE1 9HA

Website:

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