Recruitment privacy notice

How we use job applicant information for Recruitment & Onboarding purposes

Purpose of this Privacy Notice

As part of any recruitment process, Trinity College London (‘Trinity’, ‘us’, ‘we’) collects and processes personal data relating to job applicants. This Privacy Notice tells you what to expect when Trinity processes your personal information for this purpose. Trinity is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does Trinity College London collect?

Trinity 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 Trinity needs to make reasonable adjustments during the recruitment process; information about your entitlement to work in the UK; and equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.

Trinity collects this information in a variety of ways. 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.

Trinity will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal record checks. Trinity 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.

How Data is stored?

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 Trinity process personal data?

Trinity needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you. In some cases, Trinity 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.

Trinity has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process.

Processing data from job applicants allows Trinity to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. Trinity may also need to process data from job applicants to respond to and defend against legal claims.

Where Trinity 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 employees or workers and has concluded that they are not.

The organisation processes health information so that it can make reasonable adjustments during the recruitment process for candidates who have a disability or health condition. This is to carry out its obligations and exercise specific rights in relation to employment.

Where the organisation processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

During the employment offer process, you may be asked to complete a DBS (Disclosure & Barring Service) application form to undertake a DBS check. The level of DBS check undertaken (basic, standard or enhanced) will be dependent on the role for which you have applied and will be selected in accordance with the prevailing guidance from the Disclosure & Barring services. It is anticipated that a DBS check will be carried out by the Trinity (or one of its partners authorised to do so on its behalf) on a periodic basis. If between the DBS review times you receive a caution/conviction/are arrested or placed on the DBS Children’s Barred list or bound over or given a conditional discharge you must inform the HR team immediately.

Trinity has a legal right to conduct DBS checks under the Rehabilitation of Offenders Act / Police Act.

For roles within SELT centres, and some other relevant roles within Trinity, where a DBS check indicates that you may have criminal convictions and offences, Trinity is obliged to seek further information about these. Where the organisation 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.

If your application is unsuccessful, Trinity will keep your personal data on file for a period of 6 months following the conclusion of any recruitment process in case there are future employment opportunities for which you may be suited.

Who has access to the data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the People and Culture 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.

Trinity will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Trinity will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

The data that we collect from you may be transferred to and stored at a destination outside of the European Economic Area (‘EEA’). It may also be processed by staff or service providers operating outside of the EEA. We will only transfer your personal data in this way in accordance with UK data protection laws.

How does Trinity protect data?

Trinity takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long does Trinity keep data?

If your application for employment is unsuccessful, Trinity will hold your data on file for 6 months after the end of the relevant recruitment process. At the end of that period, your data will be 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/or our HR information systems and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Trinity during the recruitment process. However, if you do not provide the information, Trinity may not be able to process your application properly or at all.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

Your rights under UK data protection law

Trinity is a controller of personal information for the purposes of UK data protection law.

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• require Trinity to change incorrect or incomplete data;
• require Trinity to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where Trinity is relying on its legitimate interests as the legal ground for processing; and
• ask Trinity to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override Trinity’s legitimate grounds for processing data.

If you would like to exercise any of these rights or wish to make a subject access request, please send an email to dpo@trinitycollege.com or write to us at:

Trinity College London Blue Fin Building, 110 Southwark Street London SE1 0TA

You can also contact the Information Commissioner’s Officer on 0303 123 1113 or write to them at: Information Commissioner’s Office, Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Document Owner and Approval

The Chief of People and Culture Officer is the owner of this document and is responsible for ensuring that this privacy notice is reviewed in line with the review requirements.

This policy was last updated on 21 August 2024 and is issued on a version controlled basis.

Document History