Applicant Privacy Notice | Threshold Services

: As part of our candidate application and overarching recruitment processes, Threshold will collect, process and subsequently store information about you.
This Job Applicant Privacy Notice specifically details the personal information that we will hold about you and how it is collated either before or after the recruitment process.
This applicant privacy notice is applicable to anyone who is applying to work for Threshold, whether as an employee, worker, contractor, independent consultant, intern, or a member of senior management, hereafter referred to as the ‘job applicant’ or ‘you’.
Threshold will not necessarily hold, use or share all of the types of personal data as detailed in this Privacy Notice in relation to you. The specific types of data about you that we will hold, use and share will depend on the role for which you are applying, the nature of the recruitment process, how far you progress in then recruitment process and your individual circumstances.
We are required under the provisions of data protection legislation to provide you with the information as contained within the Privacy Notice. It is therefore important that you read the Privacy Notice carefully, in conjunction with any other similar or additional information that we might provide to you from time to time about how we collect and use your data.
Should your application be successful, when you start work for us, we will provide you with a further privacy notice that explains how we dela with your personal data whilst you are working for Threshold.
: This Privacy Notice is applicable from 25 May 2018, the date in which the General Data Protection Regulations (GDPR) were legally enforceable. This Privacy Notes does not provide you with contractual rights and will be updated in accordance with evolving legislative provisions.
: Threshold Services, 432 Antrim Road, Belfast, BT15 5GB, is the ‘controller’ for the purposes of data protection law. This means that we are responsible for deciding how we hold and use personal data about you.
: Personal data refers to any information relating to a living individual who can identified, either directly or indirectly, by reference to an identifier, (for example, Name, National Insurance (NI) number, employee number, e-mail address or physical features.
Personal data can be factual, for example, contact details or date of birth, an opinion about an individual’s actions, behaviour or information that may otherwise impact that individual in a personal or business capacity.
Data Protection legislation segments personal data into the following two categories:
Personal Data that may reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental conditions, sexual life or sexual orientation, or biometric data that are used to identify an individual are known as special category data.
The rest is known as ordinary personal data.
: At the initial states of recruitment, we will collect, hold and use the following types of ordinary information about you:
Information as contained within a formal application submission or CV, to include covering letter, your name, title, contact details, national insurance number, driving licencing details, eligibility to work in the United Kingdom (UK), employment history, previous experience, gaps as identified within your employment history, current professional registrations, (e.g., Northern Ireland Social Care Counsil (NISCC)), qualifications, trainings demonstrable experience against set competences, referees’ details and their respect contact details.
Equal Opportunities monitoring information; community background, age, race, or ethnic and disability. Please note that this information is not made available to the selection panel members.
Selection information, including formal correspondence, internal notes, internal notes, the results of any written or online selection tests, if appropriate.
If you receive a conditional offer of employment, we may collect, hold and use the following additional types of personal data about you, as follows:
Pre-employment checks, to include:
Documentary evidence of your eligibility to work within the United Kingdom, (UK),
Verification of professional / educational qualifications and your requisite professional memberships,
Employment and character references,
Medical declaration, to include your pre-employment health questionnaire,
Valid driving licence, and insurance cover for business related purposes, if appropriate,
Completion of a satisfactory Access NI, where relevant to include completion of convictions and offences declaration form / self-disclosure form,
We hold this personal data, so as an employer, we are able to facilitate the following:
Process your formally submitted application form and correspond with you in respect of it,
Objectively assess as to whether you possess the required skills, experience, qualifications and training for a role within the organisation,
Make objectively informed recruitment decisions, based upon the principles of merit,
Verify the information that has been provided by you as an applicant,
Demonstrate and confirm that you have the legal right to work within the United Kingdom, (UK),
Retain appropriate records for our recruitment process and associated decisions.
: Data protection legislation provides the foundational basis and framework on which we an as an employer, can hold and use personal data. We rely on one or more of the legal grounds when we process your ordinary personal data:
We require your personal data in order to action steps as per your request to enter into a legally binding contract with you (entry into a contract), as by virtue of your application submission you are requesting the employer into a contract with you, whether this be a contract of employment, a contract for services, or another contract classification type.
Additionally, we require your personal data to ensure our compliance with a legal obligation (legal obligation), e.g. the obligation to not discriminate during our recruitment process, or the obligation to not employ an individual who does not have the requisite legal right to work within the United Kingdom (UK).
It is both necessary and a requirement for our legitimate interests (or those of a third party), your interests and fundamental rights do not override interests (legitimate interest). For example, it is in our legitimate interest to review and carefully consider your personal data, as detailed above, so that the selection panel can selection the most appropriate candidate for the advertised role.
: As an employer, Threshold will only collect, hold and use limited types of special category data about you as an applicant, during the recruitment process, as detailed below.
It is imperative to note that special category data is considered to be highly sensitive in nature, when compared to ordinary personal data. Consequently, Threshold require an additional legal basis, (as well as the legal foundations as detailed with the ordinary classification of personal data. The additional legal grounds that we rely upon to collect, hold and use your special category data is detailed below, for each particular classification of special category data.
At the initial states of recruitment, Threshold will collect, hold and use the following type of special data about you:
Equal Opportunities Monitoring Information: This data will include information about your community background, gender, age, race, ethnicity, or disability. Threshold will utilise this information to report and monitor equality of opportunity and diversity within our overarching recruitment process. Our supplementary legal basis for the utilisation of this information is that it is necessary in the public interest for the purpose of equal opportunities monitoring and is in alignment with our internal General Data Protection Regulation Policy and associated procedures.
Reasonable Adjustments for Disability / Medical Conditions: Any information that is deemed relevant to any request by you for adjustments to the recruitment process as a result of an underlying medical condition or disability. Threshold will use the information to enable us to ensure that we undertake a fair, equitable and non-discriminatory recruitment process by considering and subsequently implementing reasonable adjustments to our requirement process as appropriate. The requirement for the utilisation is information is to ensure that we are compliant with our legal obligations, specifically in relation to employment. Namely, the legal duty to note to discriminate and to action reasonable adjustments in order to accommodate a disability.
If you are shortlisted for a role, or are in receipt of a conditional offer of employment, Threshold may collect, hold and use the following ancillary types of special category personal data about you:
Pre-Employment Health Questionnaire / Medical Assessment: Threshold will collate information about your health in a pre-employment questionnaire and a subsequent medical assessment, if required. Threshold will also secure any information in respect of underlying medical conditional and adjustments that you have brought to our attention. This information will be utilised in order to assess whether you are medically fit to undertake the role for which you have applied for, fit to undertake the role with adjustments, to consider / implement suitable reasonable adjustments and to comply with internal health and safety requirements. Our additional legal grounds for utilising this information pertain to the legal obligation / execution of a legal right in relation to employment, namely, the requirement to execute reasonable adjustments to accommodate a disability, and such use is in accordance with our General Data Protection Regulation Policy and associated procedures.
Criminal Records Information – Access NI Checks: Threshold may request that criminal records checks from the statutory body, Access NI. We will use the received information in order to assess your suitability for the role and to subsequently verify the information as contained within your formally submitted application form. The additional legal basis for using this information is to ensure the requisite regulatory compliance in respect of the legal obligations in accordance with the Safeguarding Vulnerable Groups (Northern Ireland) Order 2007, the Rehabilitation of Offenders NI Order 19678, and the Rehabilitation of Offenders Exception Amendment Order CNI 2012 as amended, Part V of the Police Act 1997, and the Access NI Code of Practice.
: As an applicant, you will invariably provide the employer, i.e., Threshold, with the majority of the personal data about you that will we retain and utilise. For example, the information as compiled within your written application form, any completed assessment methodology, e.g., written or psychometric testing, and any subsequent interview process.
An element of the personal data that is retained by Threshold will be generated from internal sources during the recruitment process. For example, the convened recruitment panel may score your suitability for the recruited role and consequently record their supporting rationale for score attribution. This objective determination will confirm as to whether an applicant has been successful or not for a role.
However, please note that some of the personal data that we hold about you and consequently process, may derive from external sources.
: Recruitment Panel:
The recruitment process will involve the processing of your submitted application form and objectively assessing as to whether you have the requisite skills, experience, qualifications, and training for a role within Threshold. In order to both facilitate and enable the aforementioned process, your personal information may be shared internally. However, the internal sharing of the information will be limited to what is required by each individual to order to fulfil and appropriately execute their respective role within the recruitment process.
Recruitment Agencies:
Upon occasion, Threshold may engage recruitment agencies in order to provide Threshold with the details of suitable candidates for vacancies, to communicate with said candidates and to process all administrative correspondence in conjunction wit the recruitment process. If Threshold is in receipt of a candidate’s application details from a designated recruitment agency, Threshold will only share a candidate’s personal details that is necessary in order to enable the hiring managers to fulfil their respective function in respect of the recruitment process. The legal premise for the sharing of information, is that it is necessary for the entry into a legal contract and it is in the legitimate interest of Threshold to engage in appropriate service providers to assist hiring managers with the recruitment process.
Medical / Occupational Health Professionals:
Threshold may share any information relevant to any request by you for the implementation of reasonable adjustments to the overall recruitment process following a declaration of an underlying medical condition or disability with either medical and / or occupational health professionals to enable us as an employer to identify, what, if any, reasonable adjustments are required within the formal recruitment process and if you are appointed to the role, prior to your formal commencement.
Please note that Threshold may share the information that you have disclosed in respect of medical conditions and / or your answers in respect of a pre-employment health questionnaire, with our designated occupational health professionals. This enables Threshold to secure a medical report which will assess your fitness for the role in which you have applied for, whilst simultaneously identifying as to whether any reasonable adjustments need to be implemented, prior to your formal commencement with Threshold.
The aforementioned information may be utilised by medical and / or occupational health professionals to undertake diagnostic assessments as required and stipulated by Health and Safety legislation.
Please note the foundational legal grounds for sharing this personal data is as follows:
Necessary requirement for entry into a formalised legal contract.
It is in our legitimate interests to consider the implementation of reasonable adjustments to enable job applicants to fully participate in the recruitment and selection process, whilst assessing the fitness for work for the job applicants, to whom we have forwarded a conditional offer of employment.
It is necessary requirement in order to ensure compliance with our legal obligations and subsequently to exercise our rights within the arena of employment. Namely, ensuring not to discriminate, to implement reasonable adjustments where applicable and to ensure strict compliance with relevant health and safety legislative provisions.
Legal / Professional Advisors
Threshold may share any of your disclosed personal data that is relevant and only where appropriate with our designated legal and other professional in order to obtain and secure legal or other bespoke professional advice in respect of matters pertaining to you or in the course of legal disputes with you or other job applicants.
The legal grounds for sharing this personal data are as follows: it is in Threshold’s legitimate interests to seek advice in order to clarify our rights and obligations and appropriately defend ourselves from potential claims, it is necessary to comply with our legal obligations and exercise our legal rights within the field of employment and finally, it is essential to establish, exercise or defend legal claims / challenges.
Home Office
Threshold may share your right to work documentation with the Home Office, where necessary, to enable Threshold to verify your right to work within the United Kingdom, (UK). The supporting legal rationale for the sharing of this personal data is to ensure compliance with our legal obligation to not to employ an individual who does not have the legal right to work within the UK.
: Threshold will only ask you to provide personal data that enables us to make an objective decision as to whether you are offered the role in which you have underwent a formalised recruitment process for.
If in the eventuality, that you do not provide this information to Threshold, as the employing body, will have to make an informed decision as to whether you are forwarded a formal offer of employment. In some cases may result in Threshold not progressing your application.
Please note that as an applicant, you are under no statutory nor contractual obligation to provide same.
: Threshold will retain your personal data throughout the entirety of the recruitment process.
If your application submission is successful, following your formal commencement date with Threshold, you will be issued with an Employee Privacy Notice, which will detail the personal information that we will retain following the conclusion of the recruitment process. The said Employee Privacy Notice will also detail the duration in which Threshold will protect the personal data whilst you are working for Threshold and following your departure.
If your application is unsuccessful, or you are placed on a reserve list,
: Please note that Threshold does not accept speculative applications nor Curriculum Vitae, (CVs). If Threshold receive any of the aforementioned documents, these will be immediately disposed of in a confidential manner.
: If Threshold are in receipt of referees provided by an applicant, we require the said applicant to advise their nominated referees the personal data that the applicant is providing. Furthermore, the applicant must provide Threshold’s contact details and advise the respective referees that in the eventuality that there are any presenting concerns in respect of the personal data usage, they should contact us directly.
: As an applicant, you have a number of legal rights pertaining to your personal data. These are detailed below for your perusal:
The right to make a subject access request: This enables you as a applicant to receive certain information about how we as an legal entity, utilise your data, as well as to receive a copy of the personal data we hold about you and to check that we are lawfully processing same. As an organisation we record and treat requests for documentation pertaining to the selection process as a Subject Access Request (SAR).
The right to request that we correct incomplete or inaccurate personal data that as an organisation we hold about you, as an applicant.
The right to request that we delete or remove personal data that we hold about you where is no good reason for us as an organisation to continue to process same. You have the right to ask Threshold to delete or remove your personal data where you have exercise your right to object to processing, please refer to below, for further information.
The right to object to our processing of your personal data where we are relying on a legitimate interest (or those of a third party), and where we are unable to demonstrate a compelling reason to continue the processing.
The right to request that we restrict our processing of your personal data. This enables you to ask Threshold to suspend the processing of your personal data about you, for example, of you want Threshold to establish its accuracy or the rationale for processing same.
The right to withdraw your consent to us utilising your personal data. As detailed above, Threshold does not nominally rely on your consent as the legal basis for utilising your personal data. However, if we are relying on your consent as the legal premise for using any of your personal data and you subsequently withdraw your consent, you also have the right to request that we delete or remove your data, if we do not have another good reason to continue to use it.
The right to request that we transfer your personal data another party, in respect of data that you have provided where our legal assertion for using the data is that it is necessary for the performance of a contract or that you have consented to Threshold utilising it. This is known as the right to ‘data portability’.
: As an employer, Threshold have employed appropriate security measures in order to prevent your personal information from being accidentally, lost, used, or accessed in an unauthorised manner, altered or disclosed. In addition, Threshold will limit access to your personal information to those employees, agents, and other third parties, who only have a ‘need to know’. The aforementioned parties will only process your personal information on our specific instructions and they are subject to a duty of confidentiality.
Threshold has internal procedures to address any suspected data security breach and will notify you and the regulator of a breach, where we are legally required to do so.
: If you would like to exercise any of the aforementioned legal rights, or if you have any concerns in respect of how your personal data is being utilised, please contact the assigned Data Protection Officer, in writing, using the following details below:
Data Protection Officer, Threshold, S2 Skainos Centre, 239 Newtownards Road Belfast, BT4 1AF
Telephone: 028 90 87 13 13
E-mail: DPO@threshold-services.co.uk
If you still remain dissatisfied with Threshold’s internal complaints process, as an applicant, you have the right to progress a formal complaint submission with the Information Commissioner’s Office, (ICO), at the following address:
The Information Commissioner's Office, 10th Floor, Causeway Tower, 9 James Street, South Belfast, Co. Antrim,BT2 8DN.
Telephone: 0303 123 1114
E-mail: ni@ico.org.uk
Please note that these rights are not absolute, and, in some circumstances, we may be entitled to refuse some or all of your request.