Job Applicant Privacy Notice
BACKGROUND:
FutureLearn understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our candidates and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Information About Us
FutureLearn Limited
Private limited company registered in England under company number 08324083.
Registered Address: 1-11 Hawley Crescent, Camden Town, London, NW1 8NP, United Kingdom.
Data Protection Officer: Christoffer Valenta
Email address: legal@futurelearn.com
What Does This Notice Cover?
This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in paragraph 5, below.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in paragraph 13.
- The right to access the personal data we hold about you. Paragraph 12 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in paragraph 13 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in paragraph 13 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in paragraph 13.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in paragraph 13.
What Personal Data Do You Collect and How?
We may collect and hold some or all of the personal data set out in the table below, using the methods also set out below.
Data Collected – How We Collect the Data
In connection with your application for work with us, we will collect and store the following categories of personal information about you:
· The information you have included in your curriculum vitae and covering letter, such as name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, your desired level of remuneration, your previous remuneration including benefit entitlements, your employment history.
· Any information you provide to us during an interview.
· The results of any assessments we give you, including online tests.
· We may also collect, store and use the following types of more sensitive personal information: During the process we may inadvertently capture some special categories of personal information about you where this has been provided by you, (e.g. information relating to your racial or ethnic origin, gender, religious or philosophical beliefs).
We may also process certain special categories of information if you share any with us (e.g. information about health or condition) in order to make reasonable adjustments to enable our candidates to apply for jobs with us, to be able to take online/telephone assessments, to attend interviews/assessment centres, to prepare for starting with us (if successful) and to ensure that we comply with regulatory obligations placed on us with regard to our hiring.
We collect personal information about candidates from the following sources:
· You, the candidate.
· Recruitment agency (if applicable)
· Your named referees, from whom we collect information relating to your performance on the job, but only after you’ve accepted our conditional offer and given us consent to contact them.
· Data from third parties, if you share these with us, from publicly accessible sources such as LinkedIn.
How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following describes how we will use your personal data, and our lawful bases for doing so:
Communicating with you by email or telephone. We do this for legitimate interests – to communicate with you about the recruitment process.
We assess your CV and cover letter/application to determine your applications suitability for a particular role. We will process your personal data to assess your skills, qualifications, and suitability for the role or work that you are apply for legitimate interests in the recruitment for the role.
To monitor recruitment statistics and reporting, such as information on your national or ethnic origin, religious, philosophical or moral beliefs, or your gender or sexual orientation, for legitimate interests. The organisation processes such information to carry out its obligations in relation to employment to ensure meaningful equal opportunity.
With your permission and/or where permitted by law, we may also use your personal data, which may include contacting you by email and/or telephone with information about other upcoming jobs that you may be interested in, or our news.
The organisation will not use your data for any purpose other than the recruitment exercise for which you have applied. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in paragraph 11.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will You Keep My Personal Data?
We retain the information provided to us for a reasonable time period that allows for applicant and placement processing. Also we may retain some job candidate recruitment, applicant data that is necessary to comply with local legal and government reporting obligations.
We will retain your personal information for a period of six (6) months after we have communicated to you our decision about whether to appoint you. At the end of that period, or if you withdraw your consent for FutureLearn to hold your data during this time, your data will be deleted or destroyed. 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.
We retain interview notes for a period of three (3) months to demonstrate that we have completed the recruitment process in a fair and transparent way and to comply with local legal and government reporting obligations.
If we wish to retain your personal information on file beyond the six (6) months on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period of up to a two-year period from the time you consent. You can withdraw your consent at any time by contacting jobs@futurelearn.com
Your Responsibilities
You are under no statutory or contractual obligation to provide data to FutureLearn during the recruitment process. However, if you do not provide the information, FutureLearn may not be able to process your application properly or at all.
You are responsible for the information you provide or make available to FutureLearn, and you must ensure it is honest, truthful, accurate and not misleading in any way. You must ensure that the information provided does not contain material that is infringing on any rights of any third party and is not otherwise legally actionable.
Further, if you provide any information concerning any other person, such as individuals you provide as references (“referee”), you are responsible for providing any notices and obtaining any consents necessary for FutureLearn to collect and use that information as described in this Notice before you provide the referee’s personal information to FutureLearn.
How and Where Do You Store or Transfer My Personal Data?
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). We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
Who has Access to my Data?
Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the People & Culture (HR) team, interviewers involved in the recruitment process, hiring managers in the team with a vacancy, interview panel members, facilities and IT staff if access to the data is necessary for the performance of their roles.
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 former employers to obtain references for you.
Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in paragraph 13.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of the FutureLearn People team):
Email address: people@futurelearn.com
Telephone number: +44 203 826 5629.
Postal Address: 1-11 Hawley Crescent, Camden Town, London NW1 8NP.
We will try our best to get back to you as soon as we can, and by no later than one month within receipt of your request.
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on request.
This Privacy Notice was last updated on 31 December 2018.
