Introduction

As part of any recruitment process, Barbican Insurance Group (Barbican, we, us, our) collects and processes personal data relating to job applicants. This Privacy Notice sets out the categories of your personal data we collect, how we collect it, what we use it for and with whom we share it, in accordance with the General Data Protection Regulation (GDPR).

By personal data we mean any information relating to you such as your name or contact details. Personal data does not include data which has been anonymised, such as data from equal opportunities monitoring carried out on an anonymised basis.

Barbican is a data controller. This means that we are responsible for deciding how we hold and use personal data about you. Should you have any questions about this Privacy Notice you can contact the Data Protection Officer at dataprotection@barbicaninsurance.com.

The types of personal data about you which we may collect, store and use are set out in the table below and in each case we have specified the purpose and our ‘lawful basis’ for processing it. The law specifies certain ‘lawful bases’ for which we are allowed to use your personal data. Most commonly, we will rely on one or more of the following lawful bases for processing your personal data:

  • where it is necessary for compliance with a legal obligation to which we are subject; and/or
  • where it is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms, which require protection of your personal data.

Where relevant, we have considered whether the interests or fundamental rights and freedoms of data subjects override our legitimate interests and have concluded that they do not.

We may collect your data from a number of sources, for example your CV, application form, references from current or previous employers, academic records, pre-employment checks, P45 or interview notes.  Barbican will only seek information from third parties after any job offer to you has been made and will inform you that it is doing so.

Category of personal dataExamplesPurposeLawful basis for processingLegitimate interest (where applicable)
Contact detailsName, address, email address and telephone numberTo administer the recruitment process and to make contact with candidatesLegitimate interestsTo enable us to make contact with applicants
Recruitment informationDetails of your qualifications, skills, experience and employment historyTo assess your application, including to carry out any required background and reference checksLegitimate interestTo make recruitment decisions and maintain standards of integrity and excellence in our workforce
Details about your current remunerationInformation about your current level of remuneration, including benefit entitlementsTo assess your application and make recruitment decisionsLegitimate interestsTo make recruitment decisions and maintain standards of integrity and excellence in our workforce
Information related to your applicationTest results, feedback from interviews or other selection processes; To assess your application and make recruitment decisionsLegitimate interestsTo make recruitment decisions and maintain standards of integrity and excellence in our workforce

Special categories of personal data

Some personal data is more sensitive and requires a higher level of protection.  This is personal data which reveals or contains:

  • racial or ethnic origin
  • political opinions
  • religious and philosophical beliefs
  • trade union membership
  • genetic data
  • biometric data
  • health data
  • sex life or sexual orientation 

We will only collect and process special category personal data if we have a lawful basis for doing so and primarily because it is necessary for the purposes of carrying out our obligations and exercising specific rights in the field of employment law (employment law obligations).

However, we may also process special category data from job applicants to respond to and defend legal claims.

The special categories of data about you which we may collect, store and use are set out in the table below and in each case we have specified the purpose and our ‘lawful basis’ for processing it.

Category of personal dataExamplesPurposeLawful basis for processing
Medical/health informationDetails relating to any disability To make reasonable adjustments before and during the recruitment process and during employmentCompliance with employment law obligations
Immigration and employability informationPassport, driving licence, visa, work permitTo check your right to work in the within the relevant countryCompliance with employment law obligations

We do not require you to provide any special categories of personal data other than those outlined in the table above.  We recommend that you do not include any additional special categories of personal data in your application as it is unlikely to be relevant to the application process.

Information relating to criminal convictions and offences

For some roles, Barbican is obliged to seek information about criminal convictions and offences. Where Barbican seeks this information, it does so because it is necessary for it to carry out its legal/regulatory obligations and exercise specific rights in relation to employment law.

What if you do not provide the personal data we request?

You are not under any statutory or contractual obligation to provide data to Barbican 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.

Change of purpose

We will only use your personal data for the purposes for which we have stated (as identified in the Purpose column of the tables set out above), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for a new unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

With whom will we share your information?

Your information will be shared internally with other entities in our Group to support the recruitment process.  This includes members of the HR 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.

Barbican will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment.  Barbican will then share your data with former employers to obtain references for you, employment background check providers to conduct necessary background checks and the Disclosure & Barring Service to obtain necessary criminal records checks.  We may share your personal data with third parties, for example with a regulator or otherwise to comply with the law. 

For how long does Barbican keep data?

If your application for employment is unsuccessful, Barbican will hold your recruitment related personal data on file for 6 months after the end of the relevant recruitment process.  At the end of that period your personal data will be 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. 

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data. 

Once we no longer require your personal data for the purposes for which it was collected, we will securely destroy your personal data within 6 months of the initial application accordance with applicable laws, regulations and policies.

Your rights in relation to your information

You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:

  • request access to your personal data (commonly known as a data subject access request) and request certain information in relation to its processing
  • request rectification of your personal data
  • request the erasure of your personal data
  • request the restriction of processing of your personal data
  • object to the processing of your personal data and
  • request the transfer of your personal data to another party.

If you want to exercise one of these rights please contact the Data Protection Officer at dataprotection@barbicaninsurance.com 

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Fees

You will not usually have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is to ensure that personal data is not disclosed to any person who has no right to receive it. 

Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will make an updated copy of such Privacy Notice available on Barbican’s website.

Further information

This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data.  If you require any further information, please do not hesitate to contact the Data Protection Officer at dataprotection@barbicicaninsurance.com.

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