Privacy statement
1. Purpose of our privacy statement
1.1 Under the Data Protection Act 2018 and the General Data Protection Regulation, we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.
2. Who are we?
2.1 We are Sanctuary Housing Association and its wholly owned subsidiaries, together Sanctuary Group ("Sanctuary") one of the UK's leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ.
3. Our data protection officer
3.1 Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2 If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing data.protection@sanctuary-housing.co.uk.
4. Why are we collecting your information?
4.1 The information that you provide to us via our online recruitment portal, on your application form, curriculum vitae and covering letter and any other correspondence you submit during the course of your application to join us as an employee or worker, is required by Sanctuary in order for us to process your application appropriately and in line with current legislation. Without this information, we will not be able to consider your application.
5. What information are we collecting?
5.1 The only information which we are collecting about you is the information which you provide to us during the course of your application to join Sanctuary. This information may also be provided to Sanctuary via a third party (e.g. recruitment agency, apprenticeship organisation, online recruitment service).
5.2 Some of the information which we collect will be special categories of personal data (also called sensitive personal data), which includes information about your health and racial or ethnic origin.
6. What we are going to do with your information
6.1 The information you provide to us will be used for the following purposes:
6.1.1 it will be stored and used by us in accordance with this privacy statement and also in accordance with your rights under the Data Protection Act 2018 and the General Data Protection Regulation
6.1.2 It will be collected and used by us fairly and openly for the purpose of processing your application.
6.2 An understanding of your personal situation and individual needs will allow us to provide a tailored service that meets any physical or cultural needs that you may have.
6.3 Some of the information which we collect will be special categories of personal data (also called sensitive personal data), such as information about your ethnic background or any disability you may have. You need to be aware that we will use this information in order to ensure we deliver services in an appropriate manner. By providing us with this information, you consent to our use of this information for this purpose.
7. What is the legal basis for using your information?
7.1 In accordance with the data protection laws, we need a "legal basis" for collecting and using information about you. There are a variety of different legal basis for processing personal data which are set out in the data protection laws.
7.2 The lawful basis on which we rely in order to use the information which we collect about you for the purposes set out in this notice will be:
7.2.1 using your information is necessary for us to comply with a legal obligation to which we are subject; and
7.2.2 using your information in this way is necessary for us to consider entering in to a contract of employment with you, subject to the recruitment process.
7.3 The lawful basis on which we rely in order to use the special categories of personal data which we collect about you will be:
7.3.1 it is necessary to use that information for carrying out our obligations and rights relating to your prospective employment with us.
8. Sharing your information
Members of Sanctuary Group
8.1 Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary in relation to your application.
8.2 Your information will only be accessed by other companies in the Group where it is necessary to do so in order to provide services in relation to your application. The obligations which are set out in this notice shall apply to the other members of the Group to the same extent that they apply to us.
8.3 For more information on which companies make up Sanctuary Group, please go to www.sanctuary-group.co.uk/about-us.
Regulators and other legal obligations
8.4 We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them.
Other organisations
8.5 We may from time to time share your information with other organisations, such as candidate assessment and profiling organisations for the purpose of completing pre-employment assessments.
9. Transferring your information abroad
9.1 If you sign up for recruitment e-alerts or agree to be contacted by us directly about opportunities, we use a third party processor, Campaign Monitor, for some of our email campaigns and we transfer your information to Campaign Monitor for the purpose of sending e-marketing and communication emails to you. Campaign Monitor is a global business that is headquartered in Australia and uses a data centre located in the United States of America, so their processing of your personal data will involve a transfer of data outside the EEA.
9.2. Whenever we transfer your personal data out of the EEA in this way, we ensure a similar degree of protection is afforded to it by ensuring that we use specific contract clauses approved by the European Commission which give personal data the same protection it has in Europe. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9.3 We will not transfer any other information you provide to us outside of the European Economic Area.
10. Security of your information
10.1 The information that you provide will be stored securely on our systems and the paper based documents that you complete will be shredded. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information.
10.2 Only relevant members of staff will access the information you provide to us.
11. Can we use your information for any other purpose?
11.1 In limited circumstances we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
12. Storing your information and deleting it
12.1 We will store the personal data which you provide to us for as long as you remain a candidate. Once you are no longer a candidate of ours, we will review the information which we hold concerning you and determine whether there are any reasons why we need to continue holding that information. For example, if you ask us to keep your information in order to be considered for other opportunities with us. Once the identified purpose comes to an end, unless there is another identifiable purpose for which it is necessary to hold on to your information, we will delete your information.
13. Your rights
13.1 In relation to the information which we hold about you, you are entitled to:
13.1.1 Ask us for access to the information;
13.1.2 Ask us to rectify the information where it is inaccurate or is incomplete;
13.1.3 Ask us to erase the information and take steps to ask others who we have shared your information with to also erase it;
13.1.4 Ask us to limit what we do with your information;
13.1.5 Object to our use of your information and ask us to stop that use;
13.1.6 Instruct us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another organisation (for example, if you want the information to be sent to another housing provider).
13.2 Our obligations to comply with the above rights are subject to certain exemptions.
13.3 Where we are using your information because you have provided your consent to that use, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected.
13.4 To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing data.protection@sanctuary-housing.co.uk.
13.5 You also have the right to complain to the Information Commissioner's Office (the "ICO") if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.