Version 1.0: November 2023
Introduction
This notice sets out how we, JBR Auto Services Limited (773 Finchley Road, London, NW11 8DN) as the data controller of the personal information. We use this information in the context of your application for employment – when we use the term ‘we’, ‘us’ and ‘our’, we mean JBR Auto Services Limited and JBR Capital Limited.
What Information do we Collect and Process?
The information includes:
– 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 we need to make reasonable adjustments during the recruitment process;
– information about your entitlement to work in the UK; and
– equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
We collect this information in a variety of ways. For example, data might be contained in application forms, CVs, briefing documents/emails from recruitment agencies, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment. Alongside this, we may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records & fraud checks.
Under the Data Protection Act, we have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. This processing includes data from job applicants to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. In addition, under the Equality Act, we may process information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where we process 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, to provide our ESG reporting and to comply with regulatory and legal reporting requirements. Data that we use for this purpose is anonymised.
We are obliged to seek information about criminal convictions, potential fraud instances and offences. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.
Data Access
Your information may be shared internally for the purposes of the recruitment exercise, including HR, those involved in the recruitment, Compliance team and any other staff members where it is necessary for the performance of their roles. Externally, it will be shared with our recruitment partners for the purpose of the recruitment exercise as appropriate.
Other Sharing
Once an offer of employment has been made, we will share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks. We will also share your data with CIFAS as part of our anti-fraud checks – further information on how CIFAS will process your data can be found at www.cifas.org.uk/fpn.
Your data may be transferred to countries outside the UK to obtain employment background checks from third-party providers. We will make sure that suitable safeguards are in place before we transfer your personal information to countries outside the UK which do not have adequate protection under laws that apply to us.
Safeguards include contractual obligations imposed on the recipients of your personal information. Those obligations require the recipient to protect your personal information to the standard required in the UK. Safeguards also include requiring the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing and where the framework is the means of protection for the personal information.
We will also share your data with our Payroll, Health Insurance and other benefits providers in order to ensure that you are paid accordingly and receive appropriate benefits.
Protection of Data
We take the security of your data seriously and 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 and our recruitment partners in the proper performance of their duties. If you require further information regarding our approach, please contact our Chief Risk Officer or HR Manager.
Retention of Data
If your application for employment is unsuccessful, we will hold your data on file for six months after the end of the relevant recruitment process.
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 accordance with our Data Retention Schedule.
Your Rights
As a data subject, you have a number of rights. You can:
require us to be transparent with you about the processing that we do with your personal information;
access and obtain a copy of your data on request;
require us to change incorrect or incomplete data;
require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing.
If you would like to exercise any of these rights, please contact our Compliance function (compliance@jbrcapital.com).
If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner’s Office. You can contact the Information Commissioner’s Office at https://ico.org.uk/.
Non-Provision of Information
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we will not be able to process your application properly or at all.
