Privacy policy
Who we are
Kent County Council (KCC) collect, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. Our Data Protection Officer is Benjamin Watts.
Kent County Council’s recruitment service is delivered by Cantium Business Solutions Ltd. (Cantium), a Local Authority Trading Company owned by KCC. For further information please read the Recruitment Hub privacy notice.
About the information we collect and hold
The following table summarises the information we collect and hold for each stage of the recruitment process, how and why we do so, how we use it and with whom it may be shared.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it. The following applies to applications for jobs with KCC up to and including the shortlisting stage.
Up to and including the shortlisting stage
Information we collect | How we collect the information | Why we collect the information | How we use and share the information |
|---|---|---|---|
Your name, email address and job preferences | From you | For the performance of a contract or in order to take steps at your request prior to entering into a contract: to enable you to sign up to and receive job alerts | To enable us to notify you of job opportunities in line with your job preferences |
Your name and contact details (ie address, home and mobile phone numbers, email address | From you | Legitimate interest: to carry out a fair recruitment process Legitimate interest: to progress your application, arrange interviews and inform you of the outcome at all stages | To enable the Recruitment Team or the recruiting manager to contact you to progress your application, arrange interviews and inform you of the outcome and issue any other correspondence required To inform the recruiting manager of your application |
Your reason for application / CV and covering letter, details of your qualifications, experience, employment history (including job titles, salary, working hours) and interests | From you, in your completed application form and interview notes if relevant | Legitimate interest: to carry out a fair recruitment process Legitimate interest: to make an informed decision to shortlist for interview and (if relevant) to recruit | To make an informed recruitment decision |
Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs | From you, in a completed, anonymised equal opportunities monitoring form | From you, in a completed, anonymised equal opportunities monitoring form | To comply with our equal opportunities monitoring obligations and to follow our equality and other policies For further information, see below* |
Declaration of disability | From you in your completed application form | To comply with our legal obligations and for reasons of substantial public interest (equality of opportunity and fair treatment) Legitimate interest: to carry out a fair recruitment process | To comply with our equal opportunities monitoring obligations and to follow our equality and other policies To carry out a fair recruitment process including provision of reasonable adjustments at interview if required Shared with recruiting managers For further information see below* |
Your information regarding your criminal record | From you, in your completed application form or pre-employment tasks | To comply with our legal obligations and for reasons of substantial public interest (preventing or detecting unlawful acts, protecting the public against dishonesty) | To make an informed recruitment decision To carry out statutory checks Information shared with the DBS and other regulatory authorities as required For further information see below* |
Details of your referees | From you, in your completed application form | Legitimate interest: to carry out a fair recruitment process For positions in the regulated sector, to comply with our legal obligations to obtain regulatory references | To carry out a fair recruitment process To comply with legal/regulatory obligations Information shared with relevant managers, HR personnel Information shared with the referee(s) via ReferenceExpert (a third party supplier) in order to request references – please see their website for their privacy policy |
Before making a final decision to recruit
| Information we collect | How we collect the information | Why we collect the information | How we use and share the information |
|---|---|---|---|
| Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you form previous employers and/or education providers and/or personal referees ** | From your referees (details of whom you will have provided on your completed application form) | Legitimate interest: to make an informed decision to recruit To comply with our legal obligations Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice | To obtain the relevant reference about you To comply with legal/regulatory obligations Information shared with relevant managers and HR personnel |
| Information regarding your academic (and professional) qualifications ** | From you, from your education provider (from the relevant professional body) | Legitimate interest: to verify the qualifications information provided by you | To make an informed recruitment decision Information shared with relevant managers and HR personnel |
| Information regarding your personal reference ** | From you, from the personal referee (details of whom you will have provided on your completed application form) | Legitimate interest: to make an informed decision to recruit | To make an informed recruitment decision Information shared with relevant managers and HR personnel |
| Information regarding your professional registrations** | From you, from the registration body | To comply with our legal obligations Legitimate interest: to verify the professional registration information provided by you | To make an informed recruitment decision To carry out statutory checks Information shared with registration bodies as required |
| Information regarding your criminal record, in criminal records disclosure certificates and enhanced criminal records disclosure certificates** | From you and from the Disclosure and Barring Service (DBS) | To perform the employment contract To comply with our legal obligations Legitimate interest: to verify the criminal records information provided by you For reasons of substantial public interest (preventing or detecting unlawful acts) and protecting the public against dishonesty | To make an informed recruitment decision To carry out statutory checks Information shared with DBS and other regulatory authorities as required For further information see below* |
| Your nationality and immigration status and information from related documents such as your passport or other identification and immigration information ** | From you | To enter into/ perform the employment contract To comply with our legal obligations Legitimate interest: to maintain employment records | To carry out right to work checks Information may be shared with the Home Office |
| A copy of your driving licence ** | From you if you are appointed to a driving position | To enter into/ perform the employment contract To comply with our legal obligations To comply with the terms of our insurance | To make an informed recruitment decision To ensure that you hold a clean driving licence Information may be shared with our insurer |
| Information regarding your occupational health clearance** | From Staff Care Services | Legitimate interest: to make an informed decision to recruit To comply with our legal obligations For occupational health assessment purposes | To make an informed recruitment decision Information shared with relevant managers and HR personnel |
Before issuing a contract of employment
| Information we collect |
| Why we collect the information | How we use and share the information |
|---|---|---|---|
| Your emergency contact details | From you | To enter into/ perform the employment contract To comply with our legal obligations Legitimate interest: to maintain good employment records and good employment practice | To ensure that we hold contact details in the event of an emergency Information shared with relevant managers and HR personnel |
| Financial information including bank details, tax information, student loan status and National Insurance Number | From you | To enter into/ perform the employment contract To comply with our legal obligations | To set up your payroll record, enrol you in the appropriate pension scheme and issue a contract of employment Information shared with HMRC and Student Loans Company |
*We will comply with the additional conditions set out in the Data Protection Act which relate to criminal convictions and other special categories of personal data (sensitive personal information). Further details on how we handle sensitive personal information (and information relating to criminal convictions and offences) are set out in our Data Protection Policy and DBS Procedure (Criminal Records Policy).
**You are required by law or in order to enter into your contract of employment to provide the categories of information marked ** above to enable us to verify your right to work and suitability for the position.
It is a legitimate interest of the recruiting employer to follow recruitment best practice, to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice – but only if these are not overridden by your interests, rights or freedoms. This means we will not use your data in any way that you would not reasonably expect.
As we have a statutory and contractual basis for collecting your personal data if you do not provide the following we may be unable to progress your job application or employ you.
Personal data
Personal data includes the following:
- title
- name(s)
- address
- contact details
- date of birth
- NI number
- employment history
- qualifications/memberships/professional registrations
- referee details
- driving licence details
- bank details
- tax information
- student loan status
- ID documents.
Personal sensitive data
- convictions
- cautions
- reprimands or warnings
- nationality and immigration status
- occupational health information.
We may share your personal data and sensitive personal data with other KCC departments as required for the purpose of your application and employment.
We will share your personal data with Cantium Business Solutions Ltd. (Cantium) where it is necessary to administer the service on KCC’s behalf or where we have another legitimate interest in doing so (provided that this is not overridden by your interests).
We will share personal information with law enforcement or other authorities if required by applicable law.
We will share personal information with our professional advisers and use your information if it is necessary for the purposes of bringing or defending legal proceedings.
Applications for jobs with other organisations
The following table applies to applications for jobs with other organisations (our clients). Where you apply for roles with other organisations through our site, we will collect and share your personal data with them as summarised in the table below.
The other organisations who advertise jobs on our site are:
- GEN2 (a trading company wholly owned by KCC)
- The Education People (a trading company wholly owned by KCC)
- Invicta Law (a trading company wholly owned by KCC)
- HoldCo (a holding company wholly owned by KCC)
Where we are acting as a ‘data processor’ for these organisations please refer to their privacy notices for information on how your data is used.
Up to and including the shortlisting stage
| Information we collect | How we collect the information | Why we collect the information | How we use and share the information |
|---|---|---|---|
| Your name, email address and job preferences | From you | At your request: to enable you to sign up to and receive job alerts | To enable us to notify you of job opportunities in line with your job preferences |
| Your name and contact details (ie address, home and mobile phone numbers, email address | From you | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to contact you to progress your application, arrange interviews and inform you of the outcome and issue any other correspondence required |
| Your reason for application / CV and covering letter, details of your qualifications, experience, employment history (including job titles, salary, working hours) and interests | From you, in your completed application form and interview notes if relevant | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to make an informed recruitment decision |
| Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs* | From you, in a completed, anonymised equal opportunities monitoring form | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to comply with their equal opportunities monitoring obligations and to follow their equality and other policies |
| Declaration of disability* | From you, in a completed appliction form | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to comply comply with equal opportunities monitoring obligations and to follow equality and other policies carry out a fair recruitment process including provision of reasonable adjustments if required |
| Your information regarding your criminal record* | From you, in your completed application form | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to:
|
| Details of your referees | From you, in your completed application form | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to:
Information shared with relevant managers, HR personnel and the referee |
We will comply with the additional conditions set out in the Data Protection Act which relate to criminal convictions and sensitive personal information. Further details on how we handle sensitive personal information (and information relating to criminal convictions and offences) are set out in our Data Protection Policy and DBS Procedure (Criminal Records Policy).
Before making a final decision to recruit
| Information we collect | How we collect the information | Why we collect the information | How we use and share the information |
|---|---|---|---|
| Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you form previous employers and/or education providers and/or personal referees ** | From your referees (details of whom you will have provided on your completed application form) | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to:
|
| Information regarding your academic (and professional) qualifications ** | From you, from your education provider (from the relevant professional body) | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to: make an informed recruitment decision Information shared with relevant recruitment organisation’s managers and HR personnel |
| Information regarding your personal reference ** | From you, from the personal referee (details of whom you will have provided on your completed application form) | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to make an informed recruitment decision and carry out statutory checks Information shared with relevant recruitment organisation’s managers and HR personnel |
| Information regarding your professional registrations** | From you, from the registration body | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to make an informed recruitment decision and carry out statutory checks Information shared with DBS and other regulatory authorities as required For further information see below* |
| Information regarding your criminal record, in criminal records disclosure certificates and enhanced criminal records disclosure certificates** | From you and from the Disclosure and Barring Service (DBS) | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to make an informed recruitment decision and carry out statutory checks Information shared with DBS and other regulatory authorities as required For further information see below* |
| Your nationality and immigration status and information from related documents such as your passport or other identification and immigration information ** | From you | Contractual obligations and requirements with the recruiting organisation(s) | For the recruiting organisation to carry out right to work checks Information may be shared with the Home Office |
| A copy of your driving licence ** | From you if you are appointed to a driving position | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to make an informed recruitment decision ensure that you hold a clean driving licence Information may be shared with the recruiting organisations insurer |
| Information regarding your occupational health clearance** | From Staff Care Services | Contractual obligations and requirements with the recruiting organisation(s) | Shared with the recruiting organisation to enable them to make an informed recruitment decision Information shared with relevant recruitment organisation’s managers and HR personnel |
Before issuing a contract of employment
| Information we collect |
| Why we collect the information | How we use and share the information |
|---|---|---|---|
| Your emergency contact details | From you | Contractual obligations and requirements with the recruiting organisation(s) | To ensure the recruiting organisation holds contact details in the event of an emergency Information shared with relevant recruitment organisation’s managers and HR personnel |
| Financial information including bank details, tax information, student loan status and National Insurance Number | From you | Contractual obligations and requirements with the recruiting organisation(s) | To allow the recruiting organisation to set up your payroll record, enrol you in the appropriate pension scheme and issue a contract of employment
|
We will comply with the additional conditions set out in the Data Protection Act which relate to criminal convictions and sensitive personal information. Further details on how we handle sensitive personal information (and information relating to criminal convictions and offences) are set out in our Data Protection Policy and DBS Procedure (Criminal Records Policy).
How long your personal data will be kept
We will hold your personal information for no longer than the statutory period in which a claim arising from the recruitment process may be brought unless there is a clear business or legal reason for exceeding this period. Upon expiry any personal data will be securely destroyed.
If your application is successful, we will keep the information that is necessary in relation to your employment. Further information can be found in our employee privacy notice which is provided at offer stage.
Your rights
Under GDPR you have rights which you can exercise free of charge which allow you to:
- know what we are doing with your information and why we are doing it
- ask to see what information we hold about you (subject access request)
- ask us to correct any mistakes in the information we hold about you
- object to direct marketing
- make a complaint to the Information Commissioners Office
- withdraw consent at any time (if applicable).
Depending on our reason for using your information you may also be entitled to:
- ask us to delete information we hold about you
- have your information transferred electronically to yourself or to another organisation
- object to decisions being made that significantly affect you
- object to how we are using your information
- stop us using your information in certain ways.
We will always seek to comply with your request. However, we may be required to hold or use your information to comply with legal duties. Please note, your request may delay or prevent us delivering a service to you.
For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioners Office (ICO) on individuals’ rights under GDPR.
If you would like to exercise a right, please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Contact
Please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.
You can contact our Data Protection Officer, Benjamin Watts, at dpo@kent.gov.uk, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.
GDPR also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted on 03031 231113.
Read our corporate privacy statement.