August 2023

Recruitment Privacy Notice

1. What is this notice?

This is the ‘RecruitmentPrivacy Notice’ of AuraPower Developments Ltd. Our contact details are:

This notice applies to individuals applying to work with us, including prospective employees, workers and contractors.

We are a data ‘controller’, which means we are responsible for deciding how we hold and use your personal information.

This notice explains how and why we will collect and use your personal information in the context of the recruitment process and your rights in relation to your personal information.We may amend this notice at any time.

3. Your personal information

In this privacy notice, ‘your personal information’ means your personal data i.e. information about you from which you can be identified. The table at section 5 below lists your personal information that we may process.

Your ‘personal information’ does not include data where the identity has been removed(anonymous data).

It is important that your personal information is accurate and up to date. Please inform us if your personal information changes during the recruitment process.

3. Special categories of personal information

‘Special categories of personal information’ means information about your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; health; sex life or sexual orientation; criminal convictions, offences or alleged offences; genetic data; or biometric data for the purpose of uniquely identifying you.

Data marked * in the table at section 6 below falls within these ‘special categories’ or might disclose special categories of personal information. We must have additional legal grounds for processing special categories of personal information, and these grounds are set out in the table at section 5 below.

4. Where does your personal information come from?

Your personal information will come from you or us, and may also come from the following sources:

  • Recruitment agencies may provide us with the following personal information: your name, phone number, city of residence, places you’ve worked
  • Background check providers may provide us with the following personal information:previous convictions
  • Former employers or other referees, whom you have given us permission to contact, may provide us with the following personal information: your former title, dates of service, quality of performance
  • Medical professionals may provide us with the following personal information: confirmation of, and description of, illness e.g., because of continued absence from work

If you would like more information on the source of your personal information please contact the People Operations Team.

5. Processing your personal information

We may process your personal information during and after the recruitment process. This may include collecting your personal information, recording it, storing it, using it, amending it, destroying it and, in some circumstances, disclosing it.

In general, we process your personal information for the reasons, and on the legal grounds set out inthe following table, and also to:

  • Retain records relating to the recruitment process;
  • Establish, exercise or defend legal claims;
  • Comply with the law [or requirements of a regulator]; and / or
  • Protect your vital interests or those of another person (in exceptional circumstances, such as a medical emergency).

6. Information about criminal convictions

To enable us to make recruitment decisions and assess suitability for particular work, we will process information about criminal convictions and offences (including alleged offences) as described in this section 7.

We will process this information for our legitimate interests (in selecting suitable employees, workers and contractors), and to exercise or perform employment law rights or obligations.

Any offer of work from us in respect of the following role[s] will be subject to a satisfactory criminal record check:

  • FinanceRoles: it is in our company’s best interests to carry out a standard / enhanced disclosure check.
  • All roles: it is in our company’s and staff’s best interests to carry out a standard /  enhanced disclosure check.

7. Data necessary for the contract

The table at section 6above identifies personal information that we may need to enter a contract with you. If you don’t provide this data, we may not be able to proceed with the recruitment process or enter into the contract.

8. Statutory requirement to provide your personal information

In some circumstances, the provision of your personal information is a statutory requirement. This includes:

  • Documentation confirming your right to work in the UK – if you don’t provide this, we may not be able to enter into a contract with you.
  • The information regarding criminal convictions described at section 7 above, where we have stated in section 7 that this is a statutory requirement.

9. Sharing your personal information with third parties

We may share your personal information with the following third parties if this is required bylaw; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person:

  • Other entities in the Aura Power group of companies.
  • Health professionals and occupational health providers involved in your care, for the purposes of establishing whether you can undergo an assessment which forms part of the application process; and/or considering reasonable adjustments to the recruitment process for disabled applicants; establishing whether you will be able to carry out a function that is intrinsic to the particular work; establishing whether you are eligible for our guaranteed interview scheme for disabled applicants; and / or assessing your fitness to work if you have accepted an offer of work from us that is subject to health checks.
  • Our professional advisors.
  • Other third parties as necessary to comply with the law.

10. Automated decision-making

We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement), which have a legal or similarly significant effect on you.

11. Transferring your personal information outside the United Kingdom

We may transfer your personal information to our employees in the countries we work in for the purposes of recruitment and management of staff.There is not an adequacy decision under data protection law in respect of these counties. However, we have put in place the following measures to ensure that your personal information receives adequate protection: training on confidentiality, sharing of information only when strictly necessary.

12. Data retention

If you don’t start work with us following the recruitment process, we will retain your personal information for six months thereafter:

  • to allow us to establish, exercise or defend legal claims; and
  • for our legitimate interests – to enable us to reconsider your application and (if appropriate) contact you, if the position you applied for becomes available again. 

If you start work with us following the recruitment process, we will give you a copy of our WorkerPrivacy Notice, and will retain your personal information as detailed in theWorker Privacy Notice.

13. Your rights

You have the following rights:

  • Access: you can request a copy of your personal information that we hold, and check we are processing it lawfully.
    Correction: you can ask us to correct your personal information if you don’t think it is accurate, complete or up-to-date.
  • Deletion: you can ask us to delete your personal information, if:
    - it is no longer necessary for the purposes for which we obtain edit;
    - you withdraw your consent, and we have no other legal basis for the processing;
    - you validly object to the processing as described below;
    - we have unlawfully processed the data; or
    - we must delete the data to comply with a legal obligation.
  • Objection: if we process your personal information to perform tasks carried out in the public interest or on the basis of legitimate interests, you can object to this processing on thebasis of your particular situation. We will only then continue the processing if we have overriding legitimate grounds for this, or the processing is to establish, exercise or defend legal claims. You may also object if we process your personal information for direct marketing purposes.
  • Restriction: you can ask us to restrict our processing of your personal information if:
    - you contest the accuracy of the data (for a period that enables us to check it);
    - our processing is unlawful, but you don’t want the data deleted;
    - we no longer need the data, but you require it to establish, exercise or defend legal claims; or
    - you have objected (as above) and are awaiting confirmation as to whether we have overriding legitimate grounds for processing.
  • Transfer: if our processing is based on your consent or necessary to carry out our contract with you, and is carried out by automated means, you can request a copy of the personal information you have provided to us and the transfer of this to someone else.Where technically feasible, you can ask us to transfer it directly.
  • Complain to theInformation Commissioner: the Information Commissioner is the UK supervisory authority for data protection issues. We aim to resolve all complaints internally via [our data protection [officer / manager]] who can be contacted as described at [insert] above, but you do have the right to complain to theInformation Commissioner at any time.

Please contact our People Operations department  if you require more information on these rights, or wish to exercise any of them.