Data Controller: Xodus Group Limited ("Xodus Group")
As part of any recruitment process, Xodus Group collects and processes personal data relating to job applicants. Xodus Group is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does Xodus Group collect?
Xodus Group collects a range of information about you as per the details you provide in your application. 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 Xodus Group needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin,
Xodus Group collects 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.
Xodus Group will also collect personal data about you from third parties, such as references supplied by former employers. Xodus Group will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does the Xodus Group process personal data?
Xodus Group needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, the Xodus Group needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment in the UK starts.
Xodus Group has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Xodus Group to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. Xodus Group may also need to process data from job applicants to respond to and defend against legal claims.
Where Xodus Group relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
Xodus Group processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where Xodus Group processes other special categories of data, such as information about ethnic origin, this is for equal opportunities monitoring purposes.
If your application is unsuccessful, Xodus Group will keep your personal data on file in case there are future employment opportunities for which you may be suited for 6 months. You are free to request your data is removed any time before the end of the 6-month period.
Who has access to data?
Your information will be shared internally and with our other group entities 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.
Xodus Group and its other group entities will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Xodus Group will then share your data with former employers to obtain references for you.
Your data may be transferred outside the European Economic Area (EEA) if you have applied for a vacancy outside the EEA.
How does Xodus Group protect data?
Xodus Group takes the security of your data seriously. It has 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.
For how long does Xodus Group keep data?
If your application for employment is unsuccessful, Xodus Group will hold your data on file for 6 months after the end of the relevant recruitment process. At the end of that period, or if you request deletion before the end of this period, your data is deleted or destroyed.
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.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require Xodus Group to change incorrect or incomplete data;
- require Xodus Group to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where Xodus Group is relying on its legitimate interests as the legal ground for processing; and
- ask Xodus Group to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override Xodus Group's legitimate grounds for processing data.
If you would like to exercise any of these rights, please contact email@example.com.
If you believe that Xodus Group has not complied with your data protection rights, you can complain to the Information Commissioner. We would however welcome the opportunity to deal with any concerns you may have before you approach the ICO and we would request that you contact firstname.lastname@example.org in the first instance.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to Xodus Group during the recruitment process. However, if you do not provide the information, Xodus Group may not be able to process your application properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.
Recruitment processes are not based solely on automated decision-making.