Occam Group - Applicant Privacy Policy

---

WHO WE ARE  

 Occam Group Ltd (company number 11986732, whose registered office is at One New St, Wells, Somerset, BA5 2LA) (“we”, “us”, “our”) collects, uses and is responsible for certain personal information about you when you apply for an opportunity with us. When we do so, we are subject to the Data Protection Act 2018, and the UK General Data Protection Regulation (“Data Protection Law”). 

For the purposes of Data Protection Law, we are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. Occam Group Ltd is registered with the UK Information Commissioner’s Office under registration number ZA699702. 

PURPOSE 

This privacy policy describes how we gather, use and protect personal information about you when you apply for an opportunity with us. 

Please read this Privacy Statement carefully as it contains important information to help you understand how and why we process any personal information that you give to us. 

TERMINOLOGY USED IN THIS POLICY 

 When we refer to “personal information” in this Policy, we mean any information about an individual which can be used to identify that individual.

When we refer to “special category” personal information in this Policy, we mean types of personal information which require a higher level of protection. 

WHAT PERSONAL INFORMATION WE GATHER 

We gather the following personal information: 

• Personal contact details (name, title, telephone numbers, address, personal email addresses). 
• Date of birth. 
• Gender. 
• Bank account details. 
• Security Clearances. 
• Nationality. 
• Employment and education history. 
• References. 
• Copies of right to work documentation. 

We may also collect, store and use the following special category personal information: 

• Whether or not you have a disability for which we need to make reasonable adjustments throughout the recruitment process, and if so, the nature of that disability to the extent required to make such reasonable adjustments. 
• Criminal convictions and offences. Please see below for further information about our collection and use of such information. 

HOW INFORMATION IS GATHERED 

Information is collected: 

• Directly from you. 
• Via an employment agency. 
• During interview. 
• From referees. 

HOW WE USE YOUR PERSONAL INFORMATION 

At your request (i.e. through submission of an application) we will process personal information prior to entering into, or in order to enter into, any employment contract. 

Situations in which we may process your personal information include: 

• When assessing your suitability for employment. 
• Checking that you are legally entitled to work in the country in which you have applied to work.  
• Checking that you have, would be able to obtain, or necessary security clearance. 
• To facilitate payment of agreed expenses associated with attending interviews. 
• To set up payment arrangements for your salary and expenses should you be offered employment 
• Ensuring you will receive benefits from the start of your employment.  
• In order to comply with a legal obligation. 

The information you have provided is not used for profiling or automated decision making processes. 

If you fail to provide certain information when requested, we may not be able to process your job application either in whole or at all, or we may be prevented from complying with our legal obligations, and you may be unable to exercise your statutory rights. 

CHANGE OF PURPOSE 

If you are unsuccessful in your application, we may wish to continue to hold your personal information in case of future opportunities for which we believe you would be suitable. We will ask for your consent to keep your personal information for this purpose and you will be able to withdraw such consent at any time. 

HOW WE USE SPECIAL CATEGORY PERSONAL INFORMATION  

We process special category personal information where we need to carry out our legal obligations or exercise rights in connection with employment, or, less commonly, we may process this type of data where it is needed in relation to legal claims. 

Situations in which we may process your special category personal information are listed below:  

• To ensure we comply with your statutory rights.  
• To assess your suitability for employment.  
• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate adjustments to allow you attend interview.  
• We may use your special categories of personal information, and any information about any criminal convictions and offences, where it is needed to establish, exercise or defend legal claims. 

INFORMATION ABOUT CRIMINAL CONVICTIONS  

Owing to our involvement in work pertaining to national security, we are required by the Cabinet Office’s “Baseline Personnel Security Standard” to carry out criminal record checks using the Disclosure and Barring Service (“DBS”) (or “Disclosure Scotland” in Scotland). This is a legal requirement for us under the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (as amended). We utilise a third party to conduct these checks on our behalf. 

Whilst it is true that not all our employees and workers will be involved in work relating to national security, the fact that we operate in an open office environment means that employees and workers could find themselves working alongside individuals that are, and on this basis, we have taken the view that we have a legitimate business interest in carrying out criminal record checks for all job applicants.  

We only hold such information for such time as is necessary in order to complete the required checks, thereafter, it is deleted. 

WHO WE SHARE YOUR PERSONAL INFORMATION WITH  

We may share your personal information internally within the company in order to progress your job application and make a decision about recruitment.  

We will only disclose your personal information to third parties when the law allows us to do so. These may include, but are not limited to:  

• External organisations for the purposes of conducting pre-employment reference and employment background checks. 
• External organisations for the purposes of obtaining security clearance. 
• Former employers or other referees in order to collect references. 
• Professional advisors. 
• Regulators to ensure compliance with the law. 
• Other third parties where it is necessary in order to enter into a contract with you,  fulfil obligations of such a contract, in order to comply with a legal obligation, or where it is necessary for our interests (or those of a third party). 
• Banking providers (where making travel expense payments). 

PROTECTING YOUR INFORMATION 

Any personal information we hold about you is stored and processed in accordance with the UK General Data Protection Regulation (GDPR). As such we have put in place appropriate security measures to prevent your personal information from being used or accessed unlawfully or accidentally lost. 

In the event that we become aware of an actual or suspected data security breach, we will promptly take all necessary steps to address such breach and notify you accordingly if your personal information has been affected. 

HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT 

We will only retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed.  

If your application for employment or engagement is unsuccessful, we will (subject to any minimum statutory or other legal, tax, health and safety, reporting or accounting requirements for particular data or records) destroy your personal information after 6 months to protect against legal risk, e.g. a possible legal claim in a tribunal, County Court or High Court. 

If you have consented to us keeping your personal information on file, in case there are future suitable employment opportunities with us, we will hold your personal information for a period of time as agreed with you, or until you withdraw your consent if earlier.

If your application for employment is successful, personal information collected during the recruitment process will be retained for the duration of your employment or engagement. Our Staff Privacy Policy will then apply to you.  

Personal information which is no longer retained will be securely and effectively destroyed or permanently erased from our IT systems. 

YOUR RIGHTS AND RESPONSIBILITIES 

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 working relationship with us. 

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. 
• 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. 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). 
• Object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.  
• 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 establish its accuracy or the reason for processing it. 
• Request the transfer of your personal information to another party. 

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact us using the following email address: info@occam-group.co.uk. 

For more information about your rights, you may wish to look at the Information Commissioners Office website www.ico.org.uk. In the event you have a complaint relating to our handling of your personal information, you also have the right to lodge a complaint with the Information Commissioner. 

You will not normally 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. 

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. 

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 contact us. 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. 

HOW TO CONTACT US 

If you have any questions about this policy or how we handle your personal information, please contact us using the following email address: info@occam-group.co.uk. 

CHANGES TO THIS POLICY   

We reserve the right to update this Policy at any time.  We will upload a new policy when we make any substantial updates.