Last updated 22 July 2021
UPP Group Holdings Limited (“UPP”) and its subsidiaries collects, uses, and shares personal data relating to applicants applying for work. UPP is committed to complying with its data protection obligations.
A full list of all UPP Companies are in Appendix 1.
UPP is a “data controller”. This means that we are responsible for deciding how we hold and use personal
information about you. You are receiving this ‘Applicant Privacy Notice’ because you are applying for work with us (whether as an employee, worker, or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of recruitment, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR) and the Data Protection Act 2018.=
The best contact details to use if you have queries about this privacy notice or about our handling of your personal data generally, are as follows:
UPP Compliance Team
UPP Group Holdings Limited
12 Arthur Street
Telephone: 0207 398 7200
Data protection principles
We will comply with the data protection principles under the applicable data protection legislation when we process personal data about you.
UPP will ensure that it protects personal data by complying with a set of principles relating to processing of personal data, as set out within the applicable data protection legislation, which require personal data to be:
- Processed lawfully, fairly and in a transparent way (‘Lawfulness, fairness and transparency’).
- Collected only for specified, explicit and legitimate valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes (‘Purpose limitation’).
- Adequate, relevant, and limited to what is necessary for the purposes that we have told you about (‘Data minimisation’).
- Accurate and where necessary kept up to date (‘Accuracy’).
- Kept only as long as necessary for the purposes we have told you about and for which the data is processed (‘Storage limitation’).
- Processed securely using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction, or damage (‘Security, integrity and confidentiality’).
- UPP is also responsible for and must be able to demonstrate compliance with the principles listed above (‘Accountability’).
The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
- The information you have provided on our application form, including but not limited to your name, title, telephone number, personal email address, employment history and qualifications
- The information you have provided to us in your curriculum vitae and covering letter, if applicable
- Information and/or opinion provided to us by recruitment agencies
- Any information you provide to us during any stage of the interview process.
We may also collect, store, and use the following “special categories” of more sensitive personal information:
- Information about your physical or mental health, including whether or not you have a disability
- Information about criminal convictions and offences.
How is your personal data collected?
We collect personal data about applicants from the following sources:
- You, the applicant
- Recruitment agencies, from which we collect the following categories of data: name (only if you are short- listed for interview), employment history, qualifications, and personal email address (only if an offer of employment is going to be made). Please contact us if you require the details of the Recruitment Agency that provided us with your details.
How we will use information about you
Our obligations when using any type of personal data about you
We will only use your personal data for the following reasons:
- To assess your skills, qualifications, and suitability for the role
- To communicate with you about the recruitment process
- To keep records related to the recruitment process
- To comply with legal or regulatory requirements
- We may retain records after an unsuccessful recruitment for a limited, to contact you about another role
- The lawful basis for processing your data is to decide whether to offer a contract of employment to you, which is a legitimate business purpose.
When we have received your CV or application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the vacancy we have advertised. If you do, we will decide whether your application is strong enough to invite you for an interview. If you are invited for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role.
How we use particularly sensitive personal information
We will not usually request sensitive information about your race, nationality, ethnicity, religious, philosophical, or moral beliefs, your sexual life or orientation at the recruitment stage. If you choose to provide any particularly sensitive personal information with your application, we may use it in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example, whether adjustments need to be made during the actual interview
- We may use certain sensitive information to ensure meaningful equal opportunity monitoring and reporting.
Do we need your consent to process special categories of data about you?
In very limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like to process and the reason we need to do so, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your application to us that you agree to any request for consent from us to process your personal data.
Processing in accordance with our other policies
Any personal data processed about you (including special categories of data) will be processed in accordance with the UPP Data Protection Policy, UPP Data Retention Policy, UPP Guidelines on Data Destruction as well as in accordance with UPP’s Data Protection Guidelines on Data Processing for HR purposes.
Information about criminal convictions and offences
We do not envisage that we will process information about criminal convictions.
Automated decision making
Recruitment decisions are not based solely on automated decision-making; however, we will notify you in writing if this position changes.
We will only share your personal information with the following third parties for the purposes of processing your application: our University Partners, Workday (UK) Limited (our cloud-based software for Human Resources and Financial Management), any other entity within the UPP Group and / or third parties engaged to procure references. Personal information is shared with these parties based on our Legitimate Interests. All our third-party service providers and other entities in the group 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.
Transferring information outside the European Economic Area (EEA)
Wherever possible, we will not transfer your data outside the European Economic Area (EEA). However, there are circumstances where this may be necessary. Where this is necessary, we make sure there are appropriate safeguards in place. For example:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- We may use specific contractual clauses adopted by the European Commission
If you fail to provide personal data
If you fail to provide certain information when requested, we may be prevented from processing your application properly or at all; or from entering into a contract of employment with you if you are successful in your application; or from complying with our legal obligations (such as to ensure that you are legally entitled to work in the UK).
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another legitimate reason and that reason is compatible with the original purpose. If we need to use your personal data for another compatible purpose, we will notify you and we will explain the legal basis which allows us to do so.
We have put in place appropriate security measures to prevent your personal data from being accidentally or unlawfully used, destroyed, lost, altered, disclosed, or accessed. 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.
If your application is unsuccessful, we will hold your personal data for six months from the date we notified you of the outcome of your application so that we can, in the event of any challenge, demonstrate that we have conducted the recruitment process in a fair and transparent way. At the end of the period your personal information will be securely destroyed.
If your application for employment is successful, your personal data will be transferred to your new personnel file and retained during your employment and we will provide you with further information about how we process personal information for employment purposes.
In very limited circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Your rights and duties
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your recruitment relationship with us.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data (commonly known as a “subject access request”). This enables you to ask for and receive a copy of the personal data we hold about you.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) to process your personal data 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 data for direct marketing purposes [and where we process your personal data to make decisions solely by automated means which have legal effects or similarly significant effects.
- Withdrawal of consent. Where our processing is based on your consent (or explicit consent), you have a right to withdraw consent at any time (see below for further information about this).
- Request the transfer of your personal data to another party.
- Lodge a complaint with the UK’s Information Commissioner, or other applicable data protection regulator.
If you want to make a request in relation to these rights, please contact the UPP Compliance Team.
Unless it proves impossible or involves disproportionate effort, we will notify others to whom we have shared your data of your request to rectify, erase or restrict the processing of your personal data.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee:
- if your request for access is clearly unfounded or excessive – we may also refuse to comply with the request in those circumstances; or
- in the event that you ask for further copies of the information.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
UPP Compliance team
If you have any questions about this privacy notice or how we handle your personal data, please contact the UPP Compliance team or the UPP HR team. Their contact details are as follows: firstname.lastname@example.org or HelloHR@upp-ltd.com.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.
If you have any questions about this privacy notice, please contact:
UPP Compliance Team
UPP Group Holdings Limited
12 Arthur Street
Telephone: 0207 398 7200