This policy sets out how we collect and use personal information about you to facilitate the recruitment and onboarding process (using Greenhouse Recruitment and Greenhouse Onboarding), in accordance with The General Data Protection Regulation EU 2016/617 (The GDPR) and data protection legislation. This policy applies only to participants who will use the Service.
Please read the following carefully, to understand our practices regarding your personal data and how we will use it in respect of the Website, the App, and your use of the System.
In order to facilitate your application for employment with Illingworth Research Group Limited (Illingworth) you will access Greenhouse, which is our nominated applicant tracking system. Greenhouse is split into Greenhouse Recruiting and Greenhouse Onboarding. Greenhouse Recruiting deals with the initial stages of the application through to final interview. Greenhouse Onboarding will only be required once a candidate has been offered and accepted a job and will take them through to day one with Illingworth. In order to process your application we will collect, store and share your personal information (commonly referred to as “Processing”), making us the “Data Processor” because we hold and use personal data about you. Your location will determine the types of personal and special category data that we process.
Consenting to registering with Greenhouse
Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data.
By registering on Greenhouse (Recruitment or Onboarding), you are indicating your consent to our processing of your personal and Special Category data (including, but not limited to your name, contact details, passport details, financial and medical information for example) as described in this policy.
How you can withdraw consent?
You may change your mind and withdraw consent at any time by contacting us at firstname.lastname@example.org; but that will not affect the lawfulness of any processing carried out before you withdraw your consent. Please note that withdrawing your consent may affect our ability to carry out any requests you have made within the System such as job applications.
This policy applies to your use of:
- Greenhouse Recruiting: Website or Mobile Application (App) available on both Google Play and the Apple Store, once you have registered with this System.
- Greenhouse Onboarding: Website, once you have registered with the Greenhouse Recruiting System and been offered a job with Illingworth.
- Any of the services accessible through the Greenhouse Website or App that are available on the website or other sites of ours (Service Sites). This policy sets out the basis on which any personal or special category data we collect from you, or that you provide to us, will be processed by us.
This policy is provided in a layered format with sections relating to the following:
- Important Information and Who We Are
- The Data We Collect About You
- How Is Your Personal Data Collected?
- How We Use Your Personal Data
- Disclosures of Your Personal Data
- International Transfers
- Data Security
- Data Retention
- Your Legal Rights
- Description of Categories Of Personal Data
Important information and who we are
Illingworth Research Group Limited is the controller and is responsible for your personal data (collectively referred to as "Illingworth", "we", "us" or "our" in this policy).
Our full details are:
- Full name of legal entity: Illingworth Research Group Limited
- Email address: email@example.com
- Postal address: Hazelwood House, Tytherington Business Park, Larkwood Way, Macclesfield, SK10 2XR
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 or other competent supervisory authority of an EU member state if the website is used outside the UK.
It is important that the personal and Special Category data we hold about you is accurate and current. Please keep us informed if there are any changes during our relationship with you.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data.
- Contact Data.
- Financial Data.
- Transaction Data.
- Device Data.
- Content Data.
- Profile Data.
- Usage Data.
- Special Category Data.
We explain the categories of personal data later in the policy and we explain what Special Category data is, below.
Special category data
We collect Special Categories of Personal Data about you (this may include but is not limited to details about your race or ethnicity, religious or philosophical beliefs and information about your health). We will only collect and process Special Category Data when it is specifically required to progress your application or for reporting purposes.
How is your personal data collected
We will collect and process the following data about you:
- Information you give us. This is information (including Identity, Contact and Financial Data) you consent to giving us about you by filling in forms on the Services Sites (Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Greenhouse System using the website or if you download or register an App, subscribe to our Service, search for an App or Service, and when you use the App to apply for a job, report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
- Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
- Background check services in connection with your employment application
- Previous employment references
- Nursing and Midwifery Council registration, PIN and expiry date
- Record of previous training (ie BLS, IATA)
How we use your personal and Special Category data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal and special category data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- For reporting purposes.
Later in the policy you can read about Lawful Basis to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal and Special Category data
Depending on your location, the type of data that we collect and process from you provide may differ.
|Purpose/activity||Type of data||Lawful basis for processing|
|To register you as a new user on Greenhouse Recruiting||Identity
|To register you as a new user on Greenhouse Onboarding||Identity
Special Category Data
Performance of a contract with you
|To manage our relationship with you including notifying you of changes to the System or any Services||Identity
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
|To administer and protect our business and this System including troubleshooting, data analysis and system testing||Identity
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
Disclosures of your personal data
When you consent to providing us with your personal and Special Category data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
All information you provide to us is stored on secure servers. Information stored “at rest” on secure servers is protected using industry standard data encryption. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. Data being transmitted between you as the User (End User) and Illingworth as part of the Service is protected using industry standard encryption methods. Data stored on our servers is protected using encryption at rest and state of the art firewalls to prevent unauthorised access.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
By law we have to keep basic information about you (including but not limited to Contact, Identity, Financial and Transaction Data) for seven years after completion of your application for audit purposes.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances you have the rights, listed below, under data protection laws in relation to your personal data.
You can exercise any of these rights at any time by contacting us at Hazelwood House, Tytherington Business Park, Larkwood Way, Macclesfield, SK10 2XR OR firstname.lastname@example.org
Lawful basis in order to process your personal data, we must be able to indicate the relevant lawful basis that is used to process the information. As a “Data Controller”, we must determine which lawful basis we are relying on to process your data. You can see more information on the lawful bases that are used to process your information by reviewing the Purposes for which we will use your personal and Special Category data section above.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
EEA means the European Economic Area.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal third parties
Other companies in the Illingworth Group acting as joint controllers or processors and who are based in Spain, France, Italy, Australia and the United States of America and provide IT and system administration services and undertake leadership reporting.
External third parties
Service providers acting as processors who provide IT and system administration services.
Applicant tracking system service providers acting as processors or controllers that provide a secure server that stores applicant data.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers base in the UK or globally who require reporting of processing activities in certain circumstances.
Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Description of categories of personal data
- Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, passport information including number, name, country of issue and expiry date.
- Contact Data: home address, email address, telephone numbers and emergency contact details.
- Financial Data: bank account details.
- Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device),] mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting information.
- Content Data: includes information stored on your Device, including photos, videos or other digital content;
- Profile Data: includes your username and password, in-System request history, your preferences and feedback.
- Usage Data: includes details of your use of any of our Systems or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Special Category data
Certain types of particularly sensitive personal data are subject to additional protection under the GDPR.
These types of data are listed under Article 9 of the GDPR as “Special Categories” of “Personal Data”. The Special Categories are:
- Personal Data revealing racial or ethnic origin.
- Political opinions
- Religious or philosophical beliefs.
- Trade union membership.
- Genetic data and biometric data processed for the purpose of uniquely identifying a person.
- Data concerning health.
- Data concerning a person’s sex life or sexual orientation.