GFM Holdings Ltd/GFM Clear Communications LTD Recruitment Privacy Policy
Our contact details.

Data Controller: GFM Holdings Ltd
Data Protection officer: Rob Mclaughlin
Address: 42 Phoenix Court, Hawkins Road, Colchester, Essex, CO2 8JY
Phone Number: 01206 791733
E-mail: dpo@gfm.co.uk

As part of any recruitment process, GFM/Clear Communications Ltd collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

The type of personal information we collect

We currently collect and process the following information:
• Your name, address and contact details, including email address and telephone number
• Details of your qualifications, skills, experience and employment history
• Information about your current level of remuneration, including benefit entitlements
• Whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process
• Information about your entitlement to work in the UK.

For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

We may also collect personal data about you from third parties, such as references supplied by former employers. We will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so. Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:
• Recruiting you for employment
• Confirming your UK right to work

Why does GFM/GFM Clear Communications process personal data?

We need to process data as part of the recruitment process. In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, it is mandatory to check a successful applicant’s eligibility to work in the UK before employment starts.

GFM/GFM Clear Communications Ltd has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.

We may also need to process data from job applicants to respond to and defend against legal claims. GFM/GFM Clear Communications Ltd may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. We process such information to carry out its obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, GFM/Clear Communications Ltd may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before we keep your data for this purpose and you are free to withdraw your consent at any time.

Please note that where you are successful in your application, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. How we use such information during your employment will be provided to you in a separate employment privacy notice.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the , interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles. We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks.

We may share your information with:
Your information may be shared internally for the purposes of the recruitment exercise. This includes interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles. We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks.

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

(a) Your consent. You are able to remove your consent at any time. You can do this by contacting Noel Murphy – Noel.murphy@gfm.co.uk [should this be DPO?]
(b) We have a contractual obligation.
(c) We have a legal obligation.
(d) We have a vital interest.
(e) We have a legitimate interest.

How we store your personal information

Your information is securely stored at 42 Phoenix Court, Hawkins Road, Colchester, Essex, CO2 8JY.

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. If you are unsuccessful in the application process, we will retain your personal data for a period of 6 months from the date of your job application. We retain your personal data for that period:

a. so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way; and
b. to write to you with details of any other vacancies which may arise in the future which we feel you might be interested in.
If you are successful in the application process and you start working with us, we will retain your personal data as set out above.
If in the future we intend to process your personal data for a purpose other than that which it was collected we will provide you with information on that purpose and any other relevant information.

Your data protection rights

Under data protection law, you have rights including:
• Your right of access – You have the right to ask us for copies of your personal information.
• Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. We may ask you to verify your identity to process your request. Please provide as much information as possible when making a request.

Please contact us at hello@gfm.co.uk, 42 Phoenix Court, Hawkins Road, Colchester, Essex, CO2 8JY, 01206 791733 if you wish to make a request.

If you have a concern about our use of your personal data you should write us.
For questions please contact the Data Protection Officer at: dpo@gfm.co.uk.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at dpo@gfm.co.uk
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by law.