The Police Digital Service (PDS) is a ” controller” of any personal data we collect and use about you during any recruitment campaign. This means that we are responsible for deciding how we hold and use that personal data about you.
As part of any recruitment process, the PDS collects and processes personal data relating to job applicants. The PDS is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information do we ask for and why?
As part of your application process, the PDS collects and uses a range of information about you in order to assess your suitability for employment.
We do not collect more information than we need to fulfil our stated purposes and will not keep it longer than necessary. You don’t have to provide the information we ask for but it may affect your application if you don’t.
We will use any feedback you provide about our recruitment process to develop and improve our future recruitment campaigns.
If you use our online application system, your details will be collected by our data processor Vacancy Filler on our behalf.
We ask you for your personal details including name and contact details. We will also ask you about previous experience and skills, employment history, education and qualifications and for answers to questions relevant to the role. Our recruitment team and hiring managers will have access to all this information.
You will also be asked to provide equal opportunities information. This is not mandatory – if you don’t provide it, it won’t affect your application. We won’t make the information available to any staff, including hiring managers, outside our recruitment team in a way that can identify you. Any information you provide will be used to produce and monitor equal opportunities statistics.
Our recruitment team (assisted on occasion by hiring managers) shortlist applications for interview using the information that you have provided in your application. To be clear, your equal opportunities information will not be used as part of the shortlisting process.
We may ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; attend an interview; or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by us.
If you are unsuccessful after assessment for the role, we may ask if you would like your details retained in our talent pool. If you say yes, we would proactively contact you should any further suitable vacancies arise.
If we make a conditional offer of employment, we’ll ask you for information so that we can carry out pre-employment checks, including to undertake (via our third party providers) criminal records checks, police vetting (including a Disclosure and Barring Service (“DBS”) check) and security clearance. We must confirm the identity of our staff and their right to work in the United Kingdom (“UK”), and seek assurance as to their trustworthiness, integrity and reliability.
You must therefore provide:
- proof of your identity;
- proof of your address;
- your National Insurance number;
- proof of your qualifications (where the qualification is a pre-requisite for the role).
Where our third party providers undertake vetting and clearance checks on our behalf, those providers will collect the information that they need from you and any information that you provide to them for this purpose will not be shared with us. Also, we are only told if an individual has passed or failed a particular check; we are not informed of the specific reasons for that outcome.
We’ll contact your referees, using the details you provide to us, directly to obtain references. We’ll also ask you:
- about any reasonable adjustments you may require under the Equality Act 2010. This information will be shared with relevant PDS staff to ensure these are in place for when you start your employment;
- for information about your current level of remuneration, including benefit entitlements;
- for information relating to your entitlement to work in the UK.
If we make a final offer, we’ll also ask you for the following:
- bank details – to process salary payments
- emergency contact details – so we know who to contact in case you have an emergency at work.
What will we do with the information you give us?
We’ll use all the information you provide during the recruitment process to progress your application with a view to offering you an employment contract with us, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide with any third parties for marketing purposes.
We’ll use the contact details you give us to contact you to progress your application. We may also contact you to request your feedback about our recruitment process. We’ll use the other information you provide to assess your suitability for the role.
How is my personal data collected?
The PDS collects this information in a variety of ways, either directly from candidates or from an employment agency. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
The PDS will also collect personal data about you from third parties, such as references supplied by former employers and information from employment background check providers. The PDS 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.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
How we make decisions about recruitment
Final recruitment decisions are made by hiring managers and members of our recruitment team. We take account of all the information gathered during the application process.
Any online testing is marked and a result is generated automatically. However, if you wish to challenge the mark you have received, the result can be checked manually.
You can ask about decisions on your application by speaking to your contact in our recruitment team or by emailing firstname.lastname@example.org.
Purpose and lawful basis for processing
Our purpose for processing this information is to assess your suitability for a role you have applied for and to help us develop and improve our recruitment process.
The lawful basis we rely on for processing your personal data is article 6(1)(b) of the General Data Protection Regulations (EU) 2016/679 (“GDPR”), which relates to processing necessary to perform a contract or to take steps at your request, before entering a contract.
If you provide us with any information about reasonable adjustments you require under the Equality Act 2010 the lawful basis we rely on for processing this information is article 6(1)(c) to comply with our legal obligations under that Act.
The lawful basis we rely on to process any information you provide as part of your application which is special category data, such as health, religious or ethnicity information is article 9(2)(b) of the GDPR, which relates to our obligations in employment and the safeguarding of your fundamental rights, and Schedule 1 part 1(1) of the Data Protection Act 2018 (“DPA”) which again relates to processing for employment purposes.
We process (via our third party provider) information about applicant criminal convictions and offences. The lawful basis we rely to process this data is Article 6(1)(f) of the GDPR, which relates to our legitimate interests. The PDS may also rely on this lawful basis to process data from job applicants to respond to and defend against legal claims.
Where the PDS relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of job applicants, employees or workers and has concluded that they are not.
How long is the information kept?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
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 your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Do we use any data processors?
Yes – we use several processors to provide elements of our recruitment service for us, including IT, conducting independent surveys about your recruitment process, advertising vacancies, collecting and storing information relating to payroll. In addition to this, we use:
- Warwickshire Vetting to undertake our vetting checks, including criminal records checks.
Do we transfer data overseas?
Your personal data may be transferred outside of the UK. Steps will be taken to ensure that any such transfers are secure and compliant with data protection laws. If you have any questions about the safeguards in place with regard to any such overseas data transfers, please contact us using the details set out below.
What are your rights?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include rights to:
- withdraw consent to processing at any time;
- receive certain information about our processing activities;
- prevent our use of your personal data for direct marketing purposes;
- ask us to erase your personal data if it is no longer necessary in relation to the purposes for which it was collected or processed or to rectify inaccurate data or to complete incomplete data;
- restrict processing in specific circumstances;
- challenge processing which has been justified on the basis of our legitimate interests or in the public interest;
- request a copy of an agreement under which personal data is transferred outside the EU;
- object to decisions based solely on automated processing, including profiling;
- prevent processing that is likely to cause damage or distress to you or anyone else;
- be notified of a personal data breach which is likely to result in high risk to your rights and freedoms;
- make a complaint to the Information Commissioner (www.ico.org.uk); and
- in limited circumstances, receive or ask for your personal data to be transferred to a third party in a structured, commonly used and machine readable format.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
To contact us, including to exercise any of your information rights, please email email@example.com.
Data Protection Officer
The PDS has appointed a Data Protection Officer. To contact our Data Protection Officer, please email firstname.lastname@example.org.