As part of any recruitment process, the firm collects and processes personal data relating to job applicants. The firm is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
Data controller: Dains Accountants Limited, 2 Chamberlain Square, Birmingham B3 3AX.
Data protection officer: Richard McNeilly, Chief Executive Officer
This policy is intended to make an applicant ("you", "your") for a position at our firm 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 UK General Data Protection Regulation (UK GDPR).
Dated: 13 August 2024 | Version: 1.5
What information does the firm collect?
The firm collects a range of information about you. This includes:
your name, address and contact details, including email address and telephone number
details of your qualifications, skills, experience, and employment history
information about your current level of remuneration, including benefit entitlements
whether or not you have a disability for which the firm needs to make reasonable adjustments during the recruitment process, and
information about your entitlement to work in the UK.
information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
information about your health, including any medical condition, health and sickness records.
information about criminal convictions and offences.
The firm may collect this information in a variety of ways. For example, data might be contained in application forms, website 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 firm may also collect personal data about you from third parties, such as third party recruitment agencies, references supplied by former employers and information from criminal records checks. The firm 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).
Why does the firm process personal data?
The firm needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.
In some cases, the firm needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
It is in our legitimate interests to decide whether to appoint you to the role for which you have applied, since it would be beneficial to our business to appoint someone to that role.
We also have a legitimate interest in keeping records of the process.
Processing data from job applicants allows the firm to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide on whom to offer a job. The firm may also need to process data from job applicants to respond to and defend against legal claims.
In summary, we will use the personal information we collect about you to:
Assess your skills, qualifications, and suitability for the role.
Carry out background and reference checks, where applicable.
Communicate with you about the recruitment process.
Keep records related to our hiring processes.
Comply with legal or regulatory requirements.
Sensitive Personal Information
We will use your particularly sensitive personal information in the following ways:
The firm may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics to ensure meaningful equal opportunity monitoring and reporting.
It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability.
The firm processes such information to carry out its obligations and exercise specific rights in relation to employment.
Information about Criminal Convictions
For some roles, the firm is obliged to seek information about criminal convictions and offences. Where the firm seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
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 carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:
The role of requires a high degree of trust and integrity since it involves dealing with client money and so we would like to ask you to seek a basic disclosure of your criminal records history.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
If your application is unsuccessful
If your application is unsuccessful, the firm may keep your personal data on file in case there are future employment opportunities for which you may be suited. The firm will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
CVs that are sent speculatively may also be kept on file for future recruitment exercises.
Who has access to data?
Sharing information internally and within our group
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles. This may also include sharing of information within The Dains group of companies where there is an appropriate reason to do this.
Sharing information with other third parties
The firm will not share your data with third parties outside of The Dains group, unless your application for employment is successful and it makes you an offer of employment. The firm will then share your data with former employers to obtain references for you and the Disclosure and Barring Service to obtain necessary criminal records checks.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Transferring your information outside of the United Kingdom
The information which you give to us may be transferred to countries outside the United Kingdom. Please see our privacy policy for more details
How does the firm protect data?
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 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.
For how long does the firm keep data?
We will retain your personal information for a period of six months after we have communicated to you our decision about whether to appoint you to 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, we will securely destroy your personal information in accordance with applicable laws and regulations.
If we wish 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, we will write to you separately, seeking your explicit consent to retain your personal information for a further 12 months.
At the end of that period (or once you withdraw your consent), your data is deleted or destroyed.
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 privacy notice.
We will retain your personal information for a period of six months after we have communicated to you our decision about whether to appoint you to 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, we will securely destroy your personal information in accordance with applicable laws and regulations.
If we wish 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, we will write to you separately, seeking your explicit consent to retain your personal information for a further 12 months.
At the end of that period (or once you withdraw your consent), your data is deleted or destroyed.
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 privacy notice.
Your rights
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 would like to exercise any of these rights, please contact Nicola Jones.
If you believe that the firm has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the firm during the recruitment process. However, if you do not provide the information, the firm may not be able to process your application properly or at all.