What is the purpose of this privacy notice?

Skipton Building Society is a Data Controller, which means we decide how we process your personal data. Here we let you know what that involves and aim to answer many of your questions. If there is anything we haven’t covered, please contact our People Team on HR@skipton.co.uk in the first instance.

You can also contact our Data Protection Officer at DPO@Skipton.co.uk or by writing to Data Protection Officer, Skipton Building Society, The Bailey, Skipton, North Yorkshire, BD23 1DN.

As a data controller, we are responsible for deciding:

1. what data we collect
2. how we use it
3. how we store it
4. when we delete it

Under the GDPR, we are required to notify you of points 1 to 4 above.

The types of personal information we may collect and hold about you

Personal data means any information about an individual from which that person can be identified. Personal data does not include anonymous data. The categories of personal data we may collect and hold about you may include:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
• Personal details such as date of birth, gender, National Insurance Number and nationality;
• CVs or cover letters or any other supplementary document included as part of the application process where requested or not;
• Information about your right to work in the UK;
• Information regarding your work history, qualifications, professional memberships, education, experience, or employment references;
• Video recordings such as those that may be submitted as part of the recruitment process (in response to specific screening questions);
• Photographs if included on CVs or otherwise on supplementary documents submitted as part of the recruitment process; and
• The results of any personality profiling assessment or testing that we may carry out as part of the recruitment process.

We may also collect, store and use the following special categories of more sensitive personal data, which could include:

• Information about whether or not you have a disability for which we need to make reasonable adjustments as part of the recruitment process; and
• Information about your ethnicity with which we may analyse themes in order to inform future inclusion decisions; and
• Information about criminal convictions and offences (where the nature of the job requires this).

How is your personal data collected/how we use it?

• We may collect this information in a variety of ways. For example, data might be collected through application forms; your CV; from correspondence with you; or through interviews, meetings or other assessments.
• We may collect personal data about you from third parties, such as references supplied by former employers or agencies and information from criminal records checks permitted by law.

Where is your personal data stored?

Your personal data will be stored securely in a range of different places, including in our recruitment files, in our HR system, and in other IT systems (including our email system). This may include third party firms who we authorise to process personal data on our behalf.

Why is your personal data processed?

Under the GDPR, a data controller should only collect your personal data if it has a valid purpose for doing so that falls into one of the prescribed categories set out in the GDPR. The purposes for which we process your data are set out below.

• Skipton Building Society requires personal data about you in order to take steps to enter into a contract of employment or service agreement with you and will retain that personal data in order to perform that contract.
• Skipton Building Society 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 us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
• In some cases, we need to process data to ensure that we are complying with our legal and regulatory obligations. For example, we are required to check a successful applicant’s eligibility to undertake a role regulated by the FCA or PRA.
• We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.
• Where we need to process other special categories of data, such as information about ethnic origin, sexual orientation, or disability, this is for equal opportunities monitoring purposes as permitted by the Data Protection Act 2018.
• For some roles, we are obliged to seek information about criminal convictions and offences. This is necessary for us to carry out our obligations and exercise specific rights in relation to employment to establish whether or not an individual has committed an unlawful act or been involved in dishonesty or other improper conduct.
• Where it is necessary to collect and process any special categories of sensitive personal data, we will ensure it is handled with the utmost discretion and will limit access to the information to the individuals who require it for the purposes of which it is being requested / processed.

If you have any questions as to why we hold any type of personal data about you, please contact the People Team or the DPO using the contact details above.

Who has access to your data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the People Team, relevant hiring managers and interviewers involved in the recruitment process, and IT staff if access to the data is necessary for the performance of their roles.

Skipton Building Society will only share your data with third parties for the purposes of assessing your application for employment. This will be with authorised third parties that have been engaged by Skipton Building Society such as, external consultants, recruitment agencies etc. If you are successful in your application and we make an offer of employment, we will ask for your nominated referees and contact them in order to obtain references for you and we will use your name within that correspondence, and we will contact a credit reporting agency to undertake necessary credit referencing checks.

Is my data secure?

We take the security of your data very seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed without authorisation, and is not accessed except by our employees/authorised third parties in the performance of their duties.

Where we engage third parties to process personal data on our behalf or we share personal data with third parties, those third parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

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.

How long do you retain my data for?

We will not hold your personal data longer than we need it. If unsuccessful, we keep your specific information related to an application for the duration of the recruitment process plus an additional 6 months thereafter. Your online applicant account will remain live for 18 months if not accessed and will then be closed but  anonymised rather than deleted in order that we can continue to report on historical activity.

If you are successful in your application, information collected as part of the recruitment process will be transferred to your personnel file and retained during your employment. Our Colleague Data Privacy Notice available to all employees details how long we will retain your employee data upon leaving employment.

Your rights

You also have the following rights when it comes to our handling of your data:

• Right of access – you have the right to request a copy of the personal data we have on you and to request supporting information explaining how the personal data is used, free of charge.
• Right of rectification – you have the right to request that we rectify inaccurate personal data about you
• Right of erasure – you have the right to request that we erase all personal data about you (please note that we may not be able to reject or restrict the request in some circumstances, depending on the information we hold and our lawful reason to keep it)
• Right to restrict processing – in some situations, you have the right to request that we do not use the personal data you have provided (e.g. if you believe it to be inaccurate)
• Right to object– you have the right to object to certain processing of your personal data (unless we have overriding compelling grounds to continue processing)
• Right to data portability – where we are relying on your consent to use your information, you have the right to require us to provide you with a copy of your information for your use or transfer to another service provider.

If you would like to exercise any of these rights, please contact our People Team using the contact details above.

If you fail to provide personal data

You are under no statutory or contractual obligation to provide data to Skipton Building Society during the recruitment process. However, if you do not provide the 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.