Recruitment Privacy Notice

About this document

15below Limited is a “data controller” when making decisions about the recruitment of employees. Being a data controller means that we are responsible for deciding how we hold and process personal information about you during the recruitment process. “Processing” includes collecting, storing, handling, sharing, transferring, accessing and deleting your personal information. This notice sets out:

i. Why we collect your personal information during the recruitment cycle;
ii. What information we ask for;
iii. What we do with the information we collect;
iv. How long we retain information for; and
v. Your rights.

1. Why do we collect your personal information?

We collect information through the application and recruitment process, either directly from you as a candidate or sometimes from an employment agency, publicly available sources or social media such as LinkedIn. We collect this information in order to progress your application, or to fulfil legal or regulatory requirements, if necessary.

There are three stages to our recruitment process:

i. Application: we ask candidates to submit CVs.

ii. Assessment: once applications have been shortlisted then we will invite shortlisted candidates for an assessment which is made up of interviews, presentations and technical assessments.

iii. Pre-employment checks: once an offer has been made to successful candidate it will be subject to obtaining satisfactory references from former employer(s). We have an equality and diversity monitoring form, which you do not have to complete and it will not affect your application if you choose not to.

2. What information do we ask for?

The information obtained during the recruitment process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
In connection with your application for work with us, we will collect, store and use the following personal information about you:

• details that appear on CVs and cover letters such as names, address and date of birth, education/professional qualifications;
• interview notes/results from assessments;
• references from former employers;
• right to work information;
• salary, benefits and bonus information for the purposes of making an offer of employment.

We will also ask whether there are any reasonable adjustments that may have to be made as part of the recruitment process in order to comply with our legal obligations.

We may also collect information about ‘special categories’ of more sensitive personal information such as your race or ethnicity, religious beliefs, disability sexual orientation for the purposes of equal opportunities monitoring.

Criminal convictions
We do not ask for information about criminal convictions as part of the recruitment process.

3. What will we do with the information you provide to us?

During the recruitment process, we will collect, store, and use information relating to right to work documentation, references and other information included in a CV or cover letter or as part of the application process.

The information obtained during the recruitment process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary. In the event you are successful we will use some of the information obtained in order to perform an employment contract with you. At this point we may provide you with other privacy notices in relation to our use of your personal data. 

We will use the other information provided to assess your suitability for the role you have applied for and for progressing your application. Should your application be successful we will need to complete on-boarding processes. We may have a need to share your information internally, and if this is required it will only be to the extent necessary to enable the recruitment process to progress.

Your information may be shared internally with employees who are involved in the recruitment for their team, employees in HR who have responsibility for recruitment and onboarding, employees in IT for user access and employees in security for access to our premises.

4. Third party data collection and sharing

We may collect and/or share your information with third party organisations such as:

• companies we work with for recruitment purposes;
• former employers/educational institutions for the purposes of obtaining references/information validation; 
• other third parties, for example with a regulator or to otherwise comply with the law; 
• permitted third-party contractors of 15below for the purposes of providing services to 15below.

The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format and will not be transferred outside of the UK or European Economic Area. We do not allow our third-party service providers to use your personal data for their own purposes.

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.

5. Processing grounds

We process your information based on a number of grounds as set out in law. Most commonly, we will use your personal information in the following circumstances:

1. Where it is necessary for our legitimate interests such as for progressing your application and for making recruitment decisions.
2. Where we need to comply with a legal obligation, such as right to work checks.
3. Where we need to perform the contract we have entered into with you in the event you are successful in your application.

We may also use your personal information here it is needed in the public interest, such as equal opportunities monitoring.

6. Automated decision making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You will not be subject to recruitment decisions based solely on automated decision-making, other than where there are objective criteria that are mandatory for the role, for example, having the Right to Work in the country where the role will be based, or possession of very specific skills that a successful candidate must have. Automated decision-making can therefore be applied without subjectivity or bias.

7. How long will you retain my information for?

Information generated throughout the recruitment process will be retained by us for 12 months either following the closure of the recruitment process or from any subsequent communication about 15below recruitment we might have with you.

If you are successful, the information you provided during the application process will be retained on your employee file for the duration of your employment plus 6 years following the end of your employment.

If we wish to retain personal information on file for future opportunities we will write to you separately and ask for your consent to retain this information.

8. Your rights

Under certain circumstances, by law you have the right to:

• See the information that we hold about you (a data subject request);
• Ask us to make a change if you think any information we hold about you is incomplete or inaccurate;
• Ask us to delete your personal information or ask us to stop/restrict the processing of your data if you believe that we should not be processing it, or we are processing it incorrectly;
• Ask us to transfer 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 our data protection officer at [email protected].

9. Compliance with this notice

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at [email protected]. You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues.

10. Complaints

If you would like to make a complaint in relation to how 15below may have stored, used or processed your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). 15below would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

11. Changes to this Privacy Notice and your duty to inform us of changes

As and when necessary, changes to this notice will be posted here. Where changes are significant, we may also email you with the new details, and where required by law, we will obtain your consent to these changes.

This notice was last updated on 11 May 2022.