Job Applicant Fair Processing / Privacy Notice

Introduction

This notice explains how and why Service Express Europe Limited (Service Express, we, us, our) use personal data relating to individuals applying for job vacancies (Applicants) through our recruitment process.

We will periodically update this policy so please check back here for any updates.

Personal Data

Personal data is information which relates to an identified or identifiable individual.

What personal data do we collect?

We collect personal data from Applicants during the application process and continuously through their engagement in the recruitment process up until the start of their engagement as a staff member. The types of data include but are not limited to:

Type of Personal Data	Information collected
Contact details	name, address, telephone number(s) and e-mail address
Personal details	date of birth, gender, and equal opportunities monitoring information (when undertaken)
ID information	photographs, passport, proof of address, driving licence details and/or other forms of official identification
Information about suitability for employment/engagement	references, interview notes, work visas and other right to work documentation, records/results of pre-employment/engagement checks (including any criminal record checks)
Skills and experience	application forms and/or CVs, records of qualifications, experience and skills, training records, information about professional memberships, portfolios
Terms and conditions	letters of offer and acceptance, contracts of employment/engagement and other HR records such as job title, working hours, location, and dates of employment or engagement
Special category data	personal data relating to racial or ethnic origin (we may also collect other types of special category data such as political opinions, religious and philosophical beliefs and sexual orientation); biometric fingerprint data (if attending one of our secure sites during the interview process), and information concerning criminal convictions and offences

How do we use personal data

We mainly use personal data relating to Applicants for communication throughout their recruitment process. However, we will also use personal data relating to Applicants where necessary to meet our legal obligations.

In addition, we will use personal data relating to Applicants where necessary for the legitimate interests of our business or the legitimate interests of a third party. Applicants have the right to object to our use of their personal data where that use is for our or a third party’s legitimate interests. We will consider all objections seriously, but where we have a strong reason to continue the use, which overrides your objection, we may do so. In that case, we would explain that decision to you.

Please see the table below which sets out the purposes, reasons, and lawful bases for processing Applicant personal data (we may also process your personal data for additional purposes in the future, but we will update this privacy notice before we do so or otherwise inform you before starting any new processing).

Purpose	Reason for collecting and processing Personal Data	Lawful basis
Recruitment	to assess suitability to work for us including both your working capacity and your right to work in the country in which you are to be conducting your duties to conduct assessments and interviews to make offers and provide contracts of employment or engagement to conduct pre-employment/engagement checks, including reference	Necessary for our legitimate interests in confirming the suitability of candidates, including the proper running of our operations To the extent the processing is provided for under our legal obligations and rights as an employer, our lawful basis will be that the processing is necessary for the performance of our legal obligations, and for any further or other processing, our lawful basis will be our legitimate interests in confirming the suitability of candidates, including the proper running of our operations
Employment/contract administration	to provide remuneration including salary, pension, sick pay and other benefits you have opted in to or not opted out for the administration of holidays and flexible working arrangements	Necessary for the performance of our legal obligations or rights or necessary for the performance of our contract with you
	to communicate with Applicants and staff and facilitate communication between staff and other people, including Applicants	Our legitimate interests in the running of our business, including our commercial interests
	to assess any injury and illness for the management of sickness absence, health & safety and to accommodate any disabilities to maintain records of any statutory maternity, paternity, adoption or shared parental leave that you may receive.	Necessary for our legal obligations and rights as an employer
Effective business management	to assess performance and fitness for work for training and education	Our legitimate interests in the running of our business including our commercial interests and the improvement of the skills of our staff
	for our diversity, inclusion and, where legally permissible, equal opportunities monitoring	Necessary for our legitimate interests including understanding our workforce and employing diversity friendly practices and for reasons of substantial public interest
	to carry out internal reviews, grievances, investigations and audits for compliance reporting	Our legitimate interests in the running of our business, including understanding and improving our operations When we undertake relevant processing activities for the purposes of meeting a legal obligation we are under, the lawful basis for those activities will be the performance of our legal obligation
Regulatory and Legal Compliance	to comply with our legal obligations, which may relate to the following (non-exhaustive): taxation (e.g. income tax information); providing you with a workplace pension; assessing whether you require any reasonable adjustments to perform your duties; assessing health and safety requirements; complying with safeguarding responsibilities; ensuring ‘right to work’ compliance; and/or complying with any requirements of regulatory bodies to complete business filings in accordance with regulatory requirements to maintain employment and HR records as required by law	Necessary for complying with legal obligations we are under
Judicial proceedings	to meet all relevant requirements arising as a result of a threatened or existing legal claim	To establish, defend, exercise or defend legal claims or meet the orders of courts acting in their judicial capacity

Please navigate to the Rights section below for an overview of your rights.

Automated decision-making

We do not use automated decision-making (including profiling).

We will share Applicant personal data with third parties where required by law, where it is necessary to administer our contract with staff or where we have legitimate interests in doing so (for example, in order to operate our business efficiently, we appoint third parties to provide specialist services to us who may need access to Applicant personal data to carry out those services). Who we share personal data relating to Applicants with will vary depending on Applicant’s roles applied for and circumstances. However, in all cases the recipients may include those set out in the table below.

Where we intend to share personal data with recipients not listed in the table below we will let Applicants know individually.

We always recommend that job applicants read third parties’ privacy notices where they are available.

Category of recipients	Includes
Official authorities	Tax authorities Government agencies
Service providers	HR, payroll, pension and benefits providers Applicant tracking and recruitment management software providers Recruitment service providers Insurance providers Landlords and office services Auditors, accountants, solicitors and other professional advisers Background check agencies
Corporate reorganisations	Potential buyers and investors
Employers	Former and future employers

We also share personal data with our group companies, including Service Express, LLC (i) as part of ongoing strategic and operational management, including the provision of HR systems for performance management; (ii) as part of our regular reporting activities on company performance (iii) for system maintenance support and hosting of data, and (iv) in the context of a business reorganisation or group restructuring exercise.

International Transfers

As part of running our operations, including sharing personal data as described above, we may transfer our Applicant’s personal data outside the UK, for example to our group company Service Express, LLC in the USA. When we transfer personal data outside the UK to a country that has not been recognised as providing an adequate level of data protection, we are required to ensure our Applicants are afforded equivalent protection in respect of their personal data to that provided in the UK.

We will put in place appropriate safeguards where necessary when making international transfers, for example, by using specific contractual measures which have been approved by the UK government together with other measures if we deem it necessary in the circumstances, for example, enhanced security. For more information about the safeguards we put in place please contact our Legal and Compliance Team at [email protected].

How long do we keep personal data?

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of Applicant’s personal data, the purposes for which we process Applicant’s and staff’s personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will only retain personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This will not usually be longer than one year after the recruitment engagement ends for the position you applied for – unless we are required by law to keep the information for a longer period.

Rights

You have various rights under data protection legislation in relation to both the personal data that we hold in relation to you and the manner in which we process it. These include being able to request a copy of your personal data, request that we erase your personal data in certain circumstances and a right to be informed about how we use your personal data.

Please see below for an overview of your key rights under data protection legislation. Please note that these rights are not absolute and there may be some situations in which they cannot be exercised or are not relevant. You can find more information about data protection rights on the Information Commissioner’s Office (ICO) website.

Legal Right	Detail
Access	You are entitled to confirmation that we process your personal data and a copy of such personal data.
Rectification	If the personal data we hold about you is incorrect, you have the right for this to be rectified.
Erasure	You can request that we erase your personal data if there is no compelling reason to continue processing.
Restriction	You may request a restriction on the processing we undertake on your personal data. This will only apply if we have no lawful basis to process your personal data, your personal data is inaccurate or to comply with an objection request (see below).
Objection	You may object to our processing of your personal data if our processing is carried out on the basis of legitimate interests. Please note, however, that should we determine that our interests are so compelling as to override your objection we may continue to process your personal data.
Portability	You have the right to receive some of your personal data in machine readable format. This right extends to you being able to request that such data is sent to a third-party controller.
Withdrawing consent	If the lawful basis we rely on to process your personal data is consent (which will be made clear to you at the point of collecting the relevant information) you have the right to withdraw this consent. Please email [the HR department] to withdraw consent for the processing of your personal data. Please note, however, that we do not generally rely on consent for the use of your personal data.
Complaining to a supervisory authority	Further information about your rights can also be obtained from your national data protection supervisory authority – in the UK, this is the ICO. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with your national data protection supervisory authority, although we would ask that you contact us in the first instance.
Right to be informed	You can contact us to find out more or to ask any questions you may have about our use of your personal data.

Contact

If you would like to contact us about this privacy notice or have any concerns about how we are using personal data, please get in touch with our Legal and Compliance Team at [email protected] or you may send requests to:

Legal and Compliance Team

Service Express Europe

Franklin Court

Priory Business Park

Bedford

MK44 3JZ

This Job Applicant Fair Processing / Privacy Notice was last updated August 25, 2023.