Candidate privacy policy

Introduction

As part of any recruitment process, Lucid Group Communications Ltd (Lucid Group) collects and processes personal data relating to job applicants. This statement contains important information about how your personal data is used by Lucid Group and your associated legal rights. Personal data is defined as information from which an individual may be identified. Lucid Group is committed to complying fully with the General Data Protection Regulation (GDPR) (EU) 2016/679 and other data protection laws. We respect the privacy rights of our applicants (past and present) and apply appropriate safeguards to protect their personal data.

1. Types of personal data

Lucid Group obtains and holds personal data relating to its job applicants, but not limited to: -

• Name, address and other contact details
• Copies of Passports, Visa and other Identity documents relating to your entitlement to work in the UK
• Information about your career history, skills, experience and qualifications
• Information about your health, medical conditions, for which we may have to make reasonable adjustments both during recruitment process and potential employment
• Unspent Criminal convictions
• References from previous employers.

2. Uses of job applicant personal data

Lucid Group, our partners, agents and suppliers, need to use and retain applicant’s data for a wide variety of purposes. These include, but are not limited to: -

• The recruitment, assessment and testing of job applicants
• Processing data and monitoring to comply with our obligations regarding discrimination
• Compliance with statutory and regulatory obligations on Lucid Group
• Managing legal disputes involving applicants, employees and/or third parties
• Exercising or fulfilling Lucid Group’s legal rights and responsibilities
• Prevention or detection of fraud, crime or other unlawful or inappropriate conduct; and

3. Disclosures of applicant data

Where necessary and lawful, your personal data may be disclosed, for example, to: -

• Lucid Group management and employees
• Our professional advisers, such as solicitors or accountants, and consultants
• Government departments and agencies
• Police and law enforcement agencies
• Courts and tribunals
• Insurers
• Partners, suppliers, agents and service providers
• Third parties to gain references.

4. Legal basis for using applicant data

In general, Lucid Group collects and uses applicant data because it is necessary for: -

• Our legitimate interests (which includes effective recruitment of employees);
• Compliance with legal obligations.

In addition, we may sometimes process applicant data, and in particular sensitive personal data eg. ethnicity, on the basis that: -

• The applicant has consented
• It is necessary to protect the vital interests of individuals or is in the public interest
• It is necessary in connection with legal claims.

Where applicant data is collected and used solely based on consent (including explicit consent) applicants have the right to withdraw consent at any time.

As an applicant you are under no legal or contractual obligation to provide your personal data to Lucid Group. However, if you do not provide the information or your consent for us to process your data, we may not be able to process your application properly or at all.

5. International transfers of data  

It is necessary for the Lucid Group to transfer some employee applicant data outside of the European Economic Area, including to jurisdictions where local legislation does not provide adequate safeguards regarding the protection and security of personal data. This will typically occur when we exchange information with our management team based in the US or when service providers, for example IT companies that need to access such data, are located outside the EEA.

Where this takes place, we will ensure that the transfer is compliant with data protection law and that the personal data is secure. In most cases, we will rely on standard data protection clauses which have been approved by the European Commission in accordance with the Regulation. A copy of the standard clauses can be obtained at the following link; https://ico.org.http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm

Where appropriate and lawful, we will occasionally transfer data outside the EEA without relying on the standard data protection clauses, including where:-

• the applicant has explicitly consented to the transfer; or;
• it is necessary in connection with legal disputes and claims.

6. Data Retention

We will not retain unsuccessful applicant data for longer than necessary and will delete it once it is no longer required for the purposes set out in the Policy. The longest we will normally hold any applicant personal data is for 1 year after the recruitment process has finished.

7. Your rights

Applicants have several statutory rights under the Regulation. They include the right to request that Lucid Group:

• Provides them with a copy of the personal data held on them
• Corrects inaccurate information
• Deletes information which Lucid Group does not have a legitimate basis to hold.

Applicants also have rights to restrict the processing of data relating to them, object to processing and in certain circumstances to ‘data portability’ (this means that data held is provided in a structured electronic, commonly used and machine-readable format).

Detailed information on these rights can be found in the Regulation or the website maintained by the Information Commissioners Office at https://ico.org.uk

These rights can be exercised free of charge and Lucid Group will normally respond within a month.
If you wish to exercise any of the above rights, please email compliance@wearelucidgroup.com.

8. Complaints

If you are unhappy about the way your personal data has been handled by the Lucid Group Communications Ltd you have the right to lodge a complaint with either our data Protection Officer or directly with the Information Commissioners Office. Further information including contact details are available at https://ico.org.uk