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Privacy Policy

St Mungo's Privacy Notice for Applicants

As part of any recruitment process, St Mungo’s (the data controller) 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.

St Mungo's Data protection officer is Maya Kotecha, 020 3856 6121, infosec@mungos.org

What information does the organisation collect?

The organisation collects a range of information about you. This includes:

  • your name, address and contact details, including email address and telephone number;
  • details of your qualifications, skills, knowledge, abilities, experience and employment history;
  • any declarations of interest including previous or current work at St Mungo’s or connections to St Mungo’s staff or Trustees
  • information about your performance in all aspects of assessment process, including job application; tests and interview;
  • 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 attendance in previous roles and / or disability or non-disability related health conditions;
  • information about your work history including any gaps;
  • information about your criminal record;
  • information about your entitlement to work in the UK;
  • equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief; and
  • your view of the assessment process.

The organisation collects this information in a variety of ways. 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, including online tests, or online surveys.  The data might also be collected from publicly available sources, such as websites.

The organisation will also collect personal data about you from third parties, such as references supplied by former employers, educational / training establishments, work experience providers or other appropriate referees as provided by yourself and information from employment background check providers and information from criminal records checks.  The organisation will seek information from third parties only once a job offer to you has been made and will inform you that it is 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).

For further information about the information collected during the recruitment process please email recruitment@mungos.org to request the Data Summary Schedule for Applicants.

Why does the organisation process personal data?

The organisation needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.  It also processes your data for the purpose of assessing its own performance through recruitment processes.

In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.

The organisation 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 the organisation to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.

Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

The organisation processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.  In addition this information is processed (along with advice from occupational health) to make a judgement in relation to whether someone is suitable for a role.

Where the organisation processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

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

Following the conclusion of any recruitment exercise, the organisation will keep your personal data on file for 9 months to respond to any questions about the process, or legal challenges.  The organisation will retain some limited information in relation to the job you applied for and equal opportunities information will be held for 15 months for reporting purposes.  In some situations, we may also keep your personal data on file in case there are future employment opportunities for which you may be suited. The organisation will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment 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 for the performance of their roles.

During the assessment process, the organisation will share your data with online test providing companies and in certain situations with assessment panel members external to St Mungo’s.  Otherwise, the organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with relevant individuals and organisations (provided by yourself) to obtain references for you, employment background check providers to obtain necessary background checks, Occupational Health Advisor to obtain any necessary health advice, the Disclosure and Barring Service to obtain necessary criminal records checks and our contract administration system to issue a contract.

Subject to the two exceptions below your data will not be processed outside of the European Economic Area (EEA).

Your data will only be processed outside of the European Economic Area (EEA) in the following circumstances:

  1. Our online test provider is based in the United States and as such data related to the online tests will be transferred outside of the EEA.  In this situation data is transferred outside of the EEA on the basis that the test provider has signed up to the EU-US Privacy Shield Framework.  More information about the Privacy Shield Framework can be found here: https://www.privacyshield.gov/welcome
  2. Where we need to obtain reference information where the referee is not based within the EEA this will require basic data transfer outside of the EEA.  In this situation you will have provided the relevant contact details for the referee.

For further information about data sharing please email recruitment@mungos.org to request the Applicants Data Sharing document.

How does the organisation protect data?

The organisation takes the security of your data seriously. It has 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.  

For how long does the organisation keep data?

If your application for employment is unsuccessful, the organisation will hold your data on file for nine months after the end of the relevant recruitment process, although we will hold a record of your name, the job you applied for and equal opportunities information for fifteen months for reporting purposes.

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. The periods for which your data will be held will be provided to you in a new privacy notice.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.

Our recruitment process requires that we contact the referees provided by you as part of our checks to ascertain suitability of employment. The content of the reference will not be shared without the referee's permission.

Your rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require the organisation to change incorrect or incomplete data;
  • require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and
  • ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation's legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact Maya Kotecha, 020 3856 6121, infosec@mungos.org.  You can make a subject access request by providing proof of your identity and outlining the scope of your request.

If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.