Last updated: June 2019
Collection of your personal information
If you apply for a job with us or are otherwise in touch with us about working for us we will collect certain personal information about you. This information may include:
- your name, home address, personal phone numbers and personal email addresses and any business contact details you provide to us
- your current job title, role details and department you work in
- your cv, including details of your education, employment history, academic and professional qualifications and memberships (including degrees awarded and transcripts), salary/pay details and similar information that you may provide to us
- information collected during phone and/or video screenings and interviews
- your professional bio including any professional social media profile (e.g. LinkedIn profile)
personal information in references about you that we receive from others (e.g. former employers and/or educational institutions)
documents evidencing your right to work including information about your nationality and immigration status and information from those documents, such as your passport or other identification number
details revealed by security screening and background checks undertaken on certain roles and/or for certain assignments (including address history, credit check results, employer/educational institution references)
personal information in applications you have made for other positions within Delaware or with one of our affiliated entities
any other personal data which you otherwise voluntarily provide
information gathered through the monitoring of our IT systems and building access records in relation to your communications with us and attendance at our premises.
We collect the majority of this personal information from you but also collect some information from third parties such as recruitment agencies, background screening service providers, your referees, your education providers, any relevant professional bodies, official bodies (such as the Home Office), credit reference agencies and relevant publicly accessible sources (e.g. Linked In). We may collect this information ourselves or via a third party agency we instruct to carry out recruitment and/or screening.
If you are applying for a post as a contractor or intern we may not collect all of the categories of personal information listed above.
Referencing and Vetting
As part of our referencing and vetting procedures, we will contact certain third parties in order to verify your personal information (including personal information that you provide as part of the application and recruitment process). These third parties will include:
- former employers in order to verify your previous employment history
- universities and/or other establishments for higher education that you attended in order to verify your education history
- credit reference agencies in order to check your credit history.
We will only seek this information in relation to successful candidates that have accepted a conditional offer of employment with us or engagement by us and we will specifically inform such candidates that we will be contacting these third parties in advance of doing so.
Use of your personal data
We use your personal information for a variety of purposes including to:
- verify your identity and candidate information and carry out employment, background and reference checks, where applicable and in order to prevent fraud
- identify and evaluate applicants, including to assess suitability as an employee or contractor
- communicate with you about the recruitment process and your application
- comply with any applicable legal or regulatory obligations
- assist with and enhance our recruitment process.
In addition to using your personal information to consider you for the role you applied for, we will process your personal information to inform you about and to consider you for other roles that may be appropriate for you. If you do not want us to consider you for other roles which we consider may be appropriate for you, please inform a member of our HR team.
Legal basis for processing
When we collect and use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.
In most cases, the legal basis will be one of the following:
- to perform a contract with you or to take steps to enter into a contract (e.g. employment contract or contract for services)
- to meet our legitimate interests or those of a third party (e.g. a recruiter who has introduced you to us)
- to comply with our legal obligations (e.g. to check your right to work in the UK or to comply with legal requirements relating to disabled applicants).
If we have asked for your consent to process your personal information, you may withdraw your consent at any time by emailing email@example.com.
Special categories of personal data
Certain categories of data including health are considered "special categories of personal data" and are subject to additional safeguards.
We will always treat special categories of personal data as confidential and will only share such data internally where there is a specific and legitimate purpose to do so. We have also implemented appropriate physical, technical, and organisational security measures designed to secure your personal information against accidental loss and unauthorised access, use, alteration, or disclosure.
We will only process information about your physical or mental health in compliance with our legal obligations to disabled applicants.
If you are successful in your application, any health information processed as part of the recruitment process that is relevant to our compliance with our obligations in connection with your employment with us or engagement by us will be retained and processed in accordance with our Employee Privacy Notice.
If you are unsuccessful in your application, any health information obtained as part of recruitment process will be deleted, together with the rest of your personal data, within 12 months of us notifying you that you have not been successful.
Sharing your personal information
In certain circumstances, we may need to share some of your personal information with other parties, such as our affiliated entities (the Delaware group), clients to whom you may be being recruited to provide services, third party service providers (including recruitment agencies, background screening agencies, and occupational health providers), relevant government bodies and our professional advisers such as our insurers and lawyers.
Outside the Delaware group and with the exception of regulators or other government bodies, your personal information will only be shared under the terms of a written agreement between us and the third party which includes appropriate security measures to protect the personal information in line with this policy and our obligations. The third parties are permitted to use the personal information only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission or as required by law.
Your personal information may be held at our offices and at those of our group entities, third party service providers etc. with whom we share your personal information. We may, in certain circumstances transfer your personal information outside the European Economic Area. In all cases, where your personal information is transferred to a third party in a country which is deemed not to have the same level of protection for personal data as the UK, we will ensure that adequate safeguards are in place to protect your personal information.
Keeping your personal information secure
We are committed to keeping your personal information secure. We have implemented appropriate information security procedures, rules and technical measures to protect the personal information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
We limit access to your personal information to those who have a genuine business need to know it. Our partners, employees, contractors, group entities, clients and third party processors may only process your personal information in an authorised manner and are subject to a duty of confidentiality.
Retaining your personal information
If you are unsuccessful in your application, we will keep your personal information for no longer than 12 months from the date on which we notify you that you have not been successful. If there is any information which (for technical reasons) we are unable to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of that information.
Your rights in relation to your personal information
We will always seek to process your personal information in accordance with our obligations and your rights.
You will not be subject to decisions based solely on automated data processing without your prior consent.
In certain circumstances, you have the right to seek the erasure or correction of your personal information, to object to particular aspects of how your personal information is processed, and otherwise to seek the restriction of the processing of your personal information. You also have the right to request the transfer of your personal information to another party in a commonly used format. If you have any questions about these rights, please contact a member of our HR team.
You have a separate right of access to your personal data processed by us. You may be asked for information to confirm your identity and/or to assist us to locate the data you are seeking as part of our response to your request. If you wish to exercise your right of access you should set out your request in writing to our HR team.
How to complain
If you have any questions about this policy or any concerns about our collection, use or sharing of your personal information, please contact a member of our HR team.
We hope that we can resolve any query or concern you raise about our use of your personal information. If not, contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.