Recruitment Privacy Notice
Introduction
As part of any recruitment process, United Utilities collects and processes personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
Who we are?
We are United Utilities Group PLC (the Group) and its subsidiaries which is a group of companies which includes United Utilities Water Limited, the water and wastewater undertaker for the North West of England.
The Group owns and operates a number of companies that look after and are separately responsible for your data (the Data Controllers). Which Data Controller you are dealing with will depend upon which part of the Group you are applying to work for. If you are unsure, please refer to the “Who can I contact about my personal data” section below.
The following is a list of all the Data Controllers within the Group:
- United Utilities Utility Solutions Limited
- United Utilities Utility Solutions (Industrial) Limited
- United Utilities International Limited
- United Utilities Pensions Trustee Limited
- United Utilities PLC
- United Utilities Property Services Limited
- United Utilities Healthcare Trustee Limited
- United Utilities Water Limited
- UU (ESPS) Pensions Trustee Limited
- United Utilities Total Solutions Limited
- United Utilities Group PLC
All of the above companies have their registered offices at Haweswater House, Lingley Mere Business Park, Lingley Green Avenue, Great Sankey, Warrington, WA5 3LP.
This Notice is intended for all prospective and actual applicants for a permanent or temporary job within the Group, including agency staff.
Any reference to “we” or “us” in this notice means any one of the above listed Data Controllers within the Group as relevant to the circumstances. Any reference to “employee” includes current permanent and temporary employee of the Group.
Please note that we may use a number of external third parties who might process your personal data on our behalf, these companies are referred to as ‘Data Processors’. Any Data Processors we use also have their own legal responsibility for handling your data. Full details of these can be obtained by contacting us (see “Who can I contact about my personal data” section below).
What information do we process?
We collect a range of information about you. This includes:
- Your name, address and contact details, including email address and telephone number
- Details of your qualifications, skills, experience and employment history
- Information about your current level of remuneration, including benefit entitlements
- Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process
- Information about your entitlement to work in the UK
- We may collect special category data (sometimes known as sensitive personal data), for example concerning ethnicity, sexual orientation or health conditions
- Where volunteered, information about your personal circumstances such as socio-economic factors for example whether your household is entitled to free school meals, educational background
- Criminal records data meaning information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings
We may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
We may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers, driver licence information from DVLA and information from criminal records checks. We will seek information from third parties only once a job offer to you has been made and will inform you of this.
Where we process special category personal data or criminal records data this is done in accordance with our policy on special categories of data and criminal records data.
We will update HR-related personal data promptly if an individual advises that his/her information has changed or is inaccurate.
Personal data gathered during the recruitment process is held in the individual's personnel file in hard copy or electronic format, or both and on HR management systems.
We keep a record of our processing activities in respect of HR-related personal data in accordance with the requirements of UK Data Protection Laws.
Data will be stored securely in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why do we process your data?
We need to process data to take steps at your request prior to entering into a contract with you.
In some cases we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts.
We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend legal claims.
We may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. We process such information to carry out our obligations and exercise specific rights in relation to employment.
Where you have volunteered information about your personal circumstances, this is for public interest reasons such as the monitoring and promotion of social mobility for less privileged candidates.
Criminal convictions and offence data (including information relating to criminal allegations and proceedings) is obtained in order to prevent and detect unlawful acts, protect the public from dishonesty and prevent fraud.
We will not use your data for any purpose other than the recruitment exercise for which you have applied.
Who has access to your data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We may then share your data with former employers to obtain references for you, we may contact employment background check providers, DVLA for driving licence checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
We may also share your personal data with selected third party organisations for research and to aid us in monitoring social mobility.
You can find out how to obtain more details about whom we share you data with from the “Who can I contact about my personal data” section below.
How do we protect your data?
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. We will ensure that our internal security measures protect your personal data in line with current UK Data Protection Laws.
For how long do we keep your data?
If your application for employment is unsuccessful, we will hold your data on file for up to one year after the end of the relevant recruitment process.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
Do we process your data abroad?
Although we are a UK company, we may sometimes use organisations outside of the UK where we have contractors working on our behalf, and as part of this they may process your personal data. When this is necessary, we will make sure there are adequate security measures in place to protect your personal data through strict contractual arrangements.
Your Data Protection Rights
In accordance with current UK data protection law you have a number of rights relating to the processing of your personal data. These rights include:
- Right of Access – this right entitles you to request a copy of any of the information we hold about you
- Right to be Informed – this right entitles you to request to be provided with details of how we process your personal data, this is the purpose of this Privacy Notice
- Right to Rectification – this right entitles you to request the correction of any personal data you believe is inaccurate or incomplete
- Right of Erasure - this right entitles you to request the deletion or removal of personal data where there is no reason for its continued processing. This right is also known as the “Right to be Forgotten”
- Right to Restrict Processing – this right entitles you to request no further processing of the personal data we have previously collected
- Right to Object – this right entitles you to request that your personal data is not processed for specific purposes such as marketing or to challenge the basis of processing your data
- Right to data portability – you have a right to ask for any personal data we hold on you electronically to be sent to another Data Controller of your choice
- Right to withdraw consent – where we have obtained your data with your consent, during the recruitment process, you have the right to withdraw that consent at any time. However this will not have affected our legal ability to process your data before you withdraw your consent
To exercise any of the above rights please see the “Who can I contact about my personal data” section below.
Please be aware there may be circumstances when we are unable to complete your request to exercise your rights. If this is ever the case we will inform you of the reason and provide details of how you can register a complaint with the Information Commissioners Office.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
Automated decision-making
Recruitment processes are not based solely on automated decision-making.
Who can I contact about my personal data?
Should you need to contact us to discuss the handling of your personal data or to submit a request to exercise your Rights please contact our Data Protection Team using one of the following methods:
Post: United Utilities, Legal Department, Grasmere House, Lingley Mere Business Park, Lingley Green Avenue, Warrington, WA5 3LP
Email: DataProtectionandFraud@uuplc.co.uk
Telephone: 0345 075 0715 and ask to be put through to the Data Protection Team in the Legal Department
How can I contact the Information Commissioner’s Office?
If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner, using the following methods:
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113 or 01625 545 745
Website: www.ico.org.uk personal data we have previously collected