Introduction

Our recruitment privacy policy tells you how we collect and process data about you if you are applying for work with us and/or if you are joining our Talent Pool. If you have any comments on this policy, please email them to [email protected].

Full Fat Things is a “data controller”, which means we are responsible for deciding how we hold and use personal information about you.

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/or your inclusion in our talent pool, and to help us develop and improve our recruitment process.

Job applicants

The lawful basis we rely on for processing your personal data for job applications is article 6(1)(b) of the UK GDPR, which relates to processing necessary to perform a contract or to take steps at your request, before entering a contract.

If you are successful with your application, your personal data will form part of your employment record. There is a separate privacy notice to support how Employees information is held, which will be shared at the appropriate time

If your application data is subsequently added to our Talent Pool, that data will be processed on the basis of your consent under Article 6(1)(a) of the UK GDPR.

Talent Pool candidates 

From time to time Full Fat Things may source candidates from publicly available information, or candidate databases to which you have submitted your details. 

The lawful basis we rely on for your inclusion in our Talent Pool is article 6(1)(f) of the UK GDPR, which relates to the legitimate interests pursued by Full Fat Things in developing a talent pool for current or future positions. If you submit your details to our Talent Pool, that data will be processed on the basis of your consent under Article 6(1)(a) of the UK GDPR. 

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 the 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 UK GDPR, which relates to our obligations in employment and the safeguarding of your fundamental rights. And Schedule 1 part 1(1) of the DPA2018 which again relates to processing for employment purposes.

The information we hold

Types of information

Full Fat Things may collect the following information of Talent Pool candidates:

• Personal information about you from a publicly available source that you control (such as a job board or a career based social media platform), insofar as such information is relevant to a potential job.

• Personal information that you make publicly available via social media may be collected if necessary.

As part of the job application process, Full Fat Things may collect the following information:

• Contact information (e.g. name, postal address and email address)

• Date of birth

• Academic and vocational qualifications, skills and competencies

• Resume/CV documents that support your job applications, including reference letters and transcripts

• Employment history

• Job application history

• Remuneration and Benefits package

• Results from any assessments and background screening we may ask you to complete

• Your responses to job-specific questions

• Information relating to how you heard about our job opportunities

• Diversity and equal opportunities information

• Marital status

• Right to eligibility

• Special adjustments required for interview
• Personal information about you from a publicly available source that you control such as job board or a career based social media platform
• Personal information that you make publicly available via social media may be collected if necessary
• Any other information you voluntarily provide to Full Fat Things

You don’t have to provide what we ask for but it may affect your application if you don’t. Our operations team will have access to all this information.

If we make a conditional offer of employment, we’ll ask you for information so that we can carry out pre-employment checks. You may therefore be asked to provide:

• proof of your identity and right to work in the UK
• proof of your qualifications
• details of referees, who we will contact directly to obtain references
• we may ask you to complete a questionnaire about your health to establish your fitness to work
• we may ask you about any reasonable adjustments you may require under the Equality Act 2010. This information will be shared with relevant staff to ensure these are in place for when you start your employment.

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
  

You may 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 outside our Operations team in a way that can identify you.

How the information is collected

We collect personal information about candidates from the following sources:

• You, the candidate from your application and assessment activities.

• Recruitment agency (if you are submitted by a third party)

• Your named referees

• Publicly available sources, such as LinkedIn and Github

• Candidate databases, to which you have submitted your details

How we use the information

We use a Talent Pool within our Applicant Tracking System to retain the details of candidates that may be interested in applying to current or future roles. We do this so that we are able to make contact regarding relevant jobs.

We’ll use the information collated 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’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.

Sensitive personal information

We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process.

We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Information sharing

We will only share your personal information with a third party if it is necessary for the purpose of the recruitment process. They 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.

Who we may share it with

We use several processors to provide elements of our recruitment service for us.

• We use Manatal to operate our Applicant Tracking System and to produce management information about campaigns. Here is a link to Manatal's privacy notice.

• We use Test Gorilla to administer and evaluate tests. Here is a link to TestGorilla’s privacy notice.

• We use The HR Dept to provide HR services. Relevant details about you may be shared in the event that their services become necessary during the application process.

• During the offer process we use Pandadoc for the purpose of administering documents and obtaining digital signatures. Here is a link to Pandadoc’s privacy notice.

• If you accept a final offer from us, some of your personnel records will be held on BreatheHR, which is an internally used HR records system. Here is a link to its privacy notice.

Data security

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.

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

We do not transfer personal data outside of the UK, European Union or European Economic Area unless we have security measures and approved contracts in place to protect your personal 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 the information is kept for

Applications

If you have applied for a role and were unsuccessful, we will usually retain a copy of your application for a period of 6 months following the completion of that recruitment campaign.

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.

We may ask if you would like your details retained in our Talent Pool. If you say yes, we will retain your information as indicated below.

Talent Pool

We will retain your personal information in our talent pool for 36 months unless either

1. we are satisfied that we will not consider recruiting you at any point in the foreseeable future

2. you ask us to remove your personal information from the talent pool

3. you have told us that we may store the data for a longer period of time

4. you are taking part in an application process, after we will retain your information as indicated for Applications.

You can request amendments or the removal of your data from the Talent Pool at any time by contacting [email protected].

How we make decisions about recruitment

Final recruitment decisions are made by hiring managers and members of our Operations 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.

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 want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us at [email protected].