Data Controller: Dains Accountants Limited, 2 Chamberlain Square, Paradise Circus, Birmingham B3 3AX.
ICO Registration Number: ZB281715
Data Protection Officer: Richard McNeilly, Chief Executive Officer
As part of our recruitment process, we collect and process personal data relating to job applicants. We use Pinpoint which is a third-party Applicant Tracking System (“ATS”) to help manage our recruitment activities. This service is provided by The Infuse Group Ltd (t/a Pinpoint Software). We use Pinpoint to process personal information as a data processor on our behalf. We remain the data controller, and Pinpoint is only entitled to process your personal data in accordance with our instructions. We are committed to being transparent about how we collect and use your data, and we strive to meet our data protection obligations under the UK GDPR and the Data Protection Act 2018.
What information do we collect?
As part of the recruitment process, we collect a range of information about you. This may include information about:
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 we need to make adjustments during the recruitment process
information about your entitlement to work in the UK
Information about criminal convictions and offences.
equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
We collect this information in a variety of ways. For example, data might be contained in application forms or CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests. In addition, the ATS may collect publicly available information from professional networking sites (e.g., LinkedIn) or similar platforms to enrich your applicant profile.
When we collect personal data about you from other third parties, such as references supplied by former employers, we will seek this information only once a job offer to you has been made.
For certain roles, we process criminal convictions data where necessary to meet our legal obligations or to exercise specific rights in relation to employment (Article 10 UK GDPR and Schedule 1, Part 1 of the Data Protection Act 2018).
Data will be stored in multiple systems, including our HR management systems, on the ATS platform, and in other IT systems (including email). Where data is processed by within the ATS, it may be transferred to and stored at datacentre locations in Amsterdam (Netherlands) and stored or backed up in London (UK). By submitting your personal data, you agree to this transfer, storing, or processing, which takes place under strict security measures and in line with our data protection obligations.
Why do we process personal data?
We process your data to take necessary steps at your request before entering into a contract with you, and to fulfil our obligations once a contract is in place.
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts.
We have a legitimate interest in processing personal data during the recruitment process and for keeping records of that process. Processing data from job applicants allows us to:
Manage the recruitment process using the ATS.
Assess and confirm a candidate’s suitability for employment.
Communicate with candidates and schedule interviews.
Decide whom to offer a job.
Respond to and defend against legal claims, if necessary.
Where we process special category data, such as health information (to make reasonable adjustments during the recruitment process) or information for equal opportunities monitoring (including ethnic origin, sexual orientation, religion or belief), we do so in compliance with the Data Protection Act 2018 under reasons of substantial public interest or to fulfil our specific rights in relation to employment.
Criminal conviction data may be processed when necessary to meet our legal or regulatory obligations or for roles requiring additional vetting.
We will not process your data for any purpose other than the recruitment exercise for which you have applied, unless such processing is required by legal or regulatory obligations.
Using our Third-Party ATS / Automated Filtering
Pinpoint will process your personal data strictly according to our instructions and does not use your data for any other purposes. We may leverage certain ATS features, such as automated matching or ranking, to help identify potentially suitable candidates based on criteria we set. No hiring decisions are made solely by automated means; our recruitment team reviews any system-generated shortlists, and the ultimate decision on your application rests with our hiring managers.
Who has access to data?
Your information will be shared internally for the purposes of the recruitment exercise. This includes:
Members of the HR and Talent Acquisition teams.
Interviewers involved in the recruitment process.
Managers in the business area with a vacancy.
IT staff if access to the data is necessary for the performance of their roles
We will not share your data with third parties, unless your application is successful and we make you an offer of employment. We will then share your data (as necessary) with former employers to obtain references for you, the Disclosure and Barring Service to obtain any criminal records checks if required, and the Home Office if necessary to conduct Right to Work checks.
As part of our use of the ATS, your data is also accessible by Pinpoint acting as a data processor. They adhere to data protection laws and cannot use your data for any purpose other than providing services on our behalf.
How do we protect data?
We take the security of your data very seriously and have implemented appropriate technical and organisational measures to safeguard your personal data against unauthorised access, alteration, or loss. These measures include, but are not limited to:
Access controls restricting who can view or process personal data.
Secure storage for physical and electronic records.
Confidentiality obligations and training for staff who handle data.
Monitoring and auditing mechanisms for data access.
When data is processed in the ATS, it is transmitted and stored with industry-standard encryption and security protocols. Although we strive to protect your personal data, please note that no transmission over the internet can be guaranteed entirely secure, and any transmission is at your own risk.
In the event of a data breach, we will notify the ICO (and affected individuals, where legally required) as soon as we become aware of the breach, in accordance with legal obligations.
For how long do we keep data?
If your application for employment is unsuccessful, we will hold your data on file for 24 months after the end of the relevant recruitment process for consideration for future employment opportunities. At the end of this period, or sooner if you withdraw your consent, your data will be deleted or destroyed.
If you submit a speculative CV, we will similarly retain your information for up to 24 months to consider you for future vacancies, unless you request us to delete it sooner.
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. Specific retention periods will be provided in a separate employee privacy notice.
You are free to object to the retention of your data or request its deletion at any time. Please contact us by:
using the Manage Your Data tool in the ATS
or,
by emailing us directly at applications@dains.com
Your rights
As a data subject, you have a number of rights. You can:
Request access to and obtain a copy of your data (“subject access request”).
Require us to change incorrect or incomplete data.
Require us to delete or stop processing your data if it is no longer needed for the purposes described in this notice.
Object to the processing of your data where we rely on our legitimate interests.
Ask us to restrict the processing of your data if you contest its accuracy or if there is a dispute about our legitimate grounds for processing.
If you would like to exercise any of these rights, please contact applications@dains.com or use the Manage Your Data tool in the ATS.
If you believe your data protection rights have been breached, you have the right to lodge a complaint with the Information Commissioner's Office (ICO). You can contact the ICO at 0303 123 1113 or via their website: www.ico.org.uk/make-a-complaint.
Automated decision-making
While the ATS may employ automated matching or filtering features to assist with managing your application, no hiring decision is based solely on automated processing. All final recruitment decisions are made by our recruitment personnel and hiring managers, taking into account the information you have provided as well as any assessments and interviews.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you choose not to provide certain information, we may not be able to process your application properly or at all. If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the UK and satisfactory references.
You are not obligated to provide information for equal opportunities monitoring purposes, and there are no consequences for your application if you opt not to provide such data.
Last Updated: 21st February 2025