Candidate Privacy Notice

1. Background

This privacy notice applies to all candidates who are applying to be employed by or otherwise work for Grant Thornton in the Channel Islands.

Grant Thornton is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during the application process, and if you are unsuccessful what we will do with your information, in accordance with the relevant data protection legislation in the jurisdictions we practice. If you are successful in your application a separate employee Data Protection Policy will apply.

According to where you are applying to in Guernsey or Jersey either Grant Thornton Services (Guernsey) Limited or Grant Thornton Services (Jersey) Limited respectively will be the “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This privacy notice is not contractual and we may update it at any time.

2. Data protection contact

We have a single point of contact for data protection queries relating to both our Jersey and Guernsey offices:

Email (preferred): data.protection@gt-ci.com

Phone: +44 1481 753434

3. The kind of information we hold about you

We will collect, store, and use the following categories of personal information about you:

1. Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
2. Date of birth.
3. Gender.
4. Marital status and dependants.
5. Remuneration and benefits history.
6. Identification information (e.g. passport details).
7. Recruitment information (including copies of right to work documentation, immigration status, references, educational & professional qualifications and other information included in a CV or cover letter or as part of the application process).
8. Details of any professional social media profiles (e.g. LinkedIn).
9. We may also collect, store and use information about criminal convictions and offences and/or information about your race, ethnicity, religious beliefs, sexual orientation and political opinions and information about your health, including any medical condition. This information is considered to be special category data.

4. How is your personal information collected?

We collect personal information about candidates through the application and recruitment process. Information comes from various sources including (but not limited to): directly from candidates; from employment agencies; from referees; or from professional social media sites. We may collect additional information from third parties including former employers or third parties who undertake background checks.

5. How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to take preparatory steps to enter into a contract with you or in order to perform a contract we have with you.
2. Where we need to comply with a legal obligation.
3. Where the processing is necessary for the purposes of exercising or performing any right or obligation conferred or imposed on us by law in connection with employment or social security.
4. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, or where it is necessary for us to establish, exercise or defend legal rights.

In addition we may also use your personal information where you have given us consent to do so or in circumstances where we need to protect your or someone else’s interests.

5.1 Situations in which we will use your personal information

We need all the categories of information in the list at section 3 above primarily to consider your application, including but not limited to putting together an offer letter, establishing your right to work, evaluating your skills, qualifications and suitability for the role and undertaking criminal records searches, and other background and reference checks and to generally conform with our regulatory and legal obligations.

It is in our legitimate interests to decide whether to appoint you to a role.

We also need to process and maintain your personal data to decide whether to enter into a contract of employment with you.

We have legal obligations to ensure your suitability for the role

5.2 If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to proceed with your application.

5.3 Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge, in compliance with the above rules, where this is required or permitted by law.

6. How will we use particularly sensitive information

”Special categories” of particularly sensitive personal information require higher levels of protection. The only form of special category information we generally process through the application process is criminal checks or medical information (in particular that is provided in order that reasonable adjustments can be made e.g. disability information).

We may only use information relating to criminal convictions where the law allows us to do so, when we are undertaking background searches or to assess your suitability to work for us. We are required to carry out such checks in order to satisfy ourselves there is nothing in your criminal conviction history which makes you unsuitable for the role as required by our legal and regulatory duties.

Where searches have been undertaken we will continue to hold such information about criminal convictions as long as it remains relevant.

7. Automated decision-making

As part of our recruitment process from time to time we use personality profiling and aptitude testing as an aid to recruitment decision making. No decisions are taken solely on an automated basis. For further information please contact a member of our People & Culture team.

8. Data sharing

We may need to share your data with third-party service providers to undertake background screening checks on our behalf, including those who may be based outside of the Channel Islands. We require third parties to respect the security of your data and to treat it in accordance with the law. If we do share your data in this way, you can expect a similar degree of protection in respect of your personal information.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained by using the contact details above.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

10. Data retention

If you are unsuccessful in your application, information will be retained for up to 12 months on the basis of legitimate interests in order to provide candidate feedback and defend legal proceedings. Further details in relation to our retention policies can be obtained from our data protection contact listed at point 2 above.

11. Rights of access, correction, erasure and restriction

11.1 Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

11.2 Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. If this request is made then the data will usually be provided to you within four weeks of the request (or such other time period as applicable under local legislation).
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it or we are not legally obliged to retain it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). In this circumstance the data will usually be erased within four weeks of the request (or such other time period as applicable under local legislation).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to verify its accuracy or the reason for processing it.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us using the details above.

11.3 No fee usually required

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

11.4 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 another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

12. Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please do so by using the contact details above. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

13. Complaints

Should you have any cause for complaint, please write to us at:

Data Protection
Grant Thornton
Kensington Chambers
46/50 Kensington Place
St. Helier JE1 1ET
Jersey

If you’re dissatisfied with the way in which your complaint has been handled you may contact your local data protection supervisory authority, or write to our local Information Commissioner:

For Jersey complaints:
The Jersey Office of the Information Commissioner
2nd Floor
5 Castle Street
St Helier
Jersey
JE2 3BT
Website: www.jerseyoic.org
Email: enquiries@jerseyoic.org

For Guernsey complaints:

Office of the Data Protection Authority
St Martin's House
La Bordage
St Peter Port
Guernsey
GY1 1BR

Web: www.odpa.gg
Email: enquiries@odpa.gg

14. Changes to this privacy notice

We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact us using the details above.