Recruitment privacy notice
What personal data do we collect?
Where you have applied for a job, work experience, fixed term contract, secondment or internship with us we will collect the following. This list is non-exclusive:
- Contact details such as name, title, addresses, telephone numbers, and personal email addresses;
- Preferred method of contact;
- Copies of driving licence, passport, birth certificates and proof of current address, such as bank statements and council tax bills;
- Notice period, preferred start date;
- Evidence of how you meet the requirements of the job, such as application forms, CVs, covering letters, references, assessment outputs, employment history, academic qualifications/history, professional training/certifications, skills, and work experience or internships;
- Evidence of your current and/or future work eligibility status, immigration status, including visa type, and visa expiry date;
- Diversity and equal opportunities monitoring information – this can include information about your race or ethnicity, religious beliefs, sexual orientation, disability and other ‘special category data’ information about your health, including any medical needs or conditions;
- Other unforeseen information required for some applications;
- If you contact us regarding your application, a record of that correspondence including, but not limited to, the content and attachments of emails;
- Details of your use of our recruitment tools and services, such as your candidate profile, the source of your application, the date/time, the role(s) you applied for, salary history/expectations, alerts for vacancies, the status of your application and updates on how it moves forward;
- Derived data about you, that is, data that includes our staff’s opinion of you such as, but not limited, to the stages you complete of the recruitment process and those you do not, records of interviews, interview notes/feedback, assessment feedback, rejection stage, rejection reason, and job offer details;
- Language and behaviour of yourself within the public domain such as social media posts (X, Meta platforms, YouTube etc.); and
- Further information you provide us in interviews, conversations and communications with us which may or may not be recorded.
We may also collect, store and use the “special categories” of more sensitive personal information including, but not limited to:
- Information about your physical or mental health, or disability status;
- Information about your health and medical conditions for health and safety reporting purposes;
- Criminal records information;
- Personal information related to the Equality Act 2010 inclusive of data known as ‘Protected Characteristics’ (age, disability, gender reassignment, marriage or civil partnership (in employment only), pregnancy and maternity, race, religion or belief, sex, sexual orientation); and
- Personal information related to our internal equality and diversity monitoring policy (geographical location, organisation, socio-economic class, caring responsibilities, educational background).
Where do we get your personal data?
We may collect personal data in a variety of ways and at a variety of times throughout our interactions with you. We refer to “direct data collection” when data is collected directly from you and we refer to “indirect data collection” when the data is not collected directly from you. Here is the list of ways we will collect your personal data from you:
- From yourself where you have responded to an advert on our website, completed our contact us page on our website or sent an unsolicited prospective email to us (direct data collection);
- From yourself via a recruitment web advert we have developed which may also mean we have received your personal data via a recruitment platform or website which you have filled in (direct data collection);
- From a recruiter, recruitment agency or other applicant tracking system or recruitment website (indirect data collection);
- We also use platforms such as LinkedIn, Indeed, CV Library and others where we may have identified you as a potential candidate for employment, work experience or internship (indirect data collection);
- Via publicly available sources such as social media, where we have identified you as an individual we would like to approach as a good fit for employment, work experience or internship (indirect data collection);
- From a reference of a sectoral relevant individual where they have gained permission from you to be introduced to us (indirect data collection);
- From a Higher Education Provider (HEP) such as a college or University who has recommended you to us (indirect data collection);
- From a current or former employee where they hold a previously established relationship with you and sharing your personal information with us would not be unexpected (indirect data collection);
- From yourself when you have participated in a survey, questionnaire, poll or related web-form as a research participant and expressed an interest, in any free-text fields, of being a potential candidate for employment, work experience or internship (indirect data collection);
- From publicly available websites and social media platforms when we think you may have an interest in a role that we have open for people to apply for (indirect data collection);
- From former employers and people named by candidates as references (indirect data collection);
- Where relevant, the Disclosure and Barring Service (DBS) and/or police records (indirect data collection);
- If relevant to the role, internal and/or Government departments or other relevant and related institutions (indirect data collection).
What do we use your personal data for and what is our lawful basis for using it?
We will use your personal data for the following purposes and on the following lawful bases.
Purpose for using personal data | Lawful basis for using |
Processing your data is necessary to move your application forward before signing a contract of work. This concerns employment or pre-employment checks | The lawful basis we shall be relying in accordance with UK GDPR Article 6.1(b) where the use your personal data is necessary in the performance of a contract which you have agreed to or where we are working to enter into a contract with you. |
To ensure compliance with employment law. | Compliance with a legal obligation under UK GDPR Article 6.1(c). The legal obligation is The Employment Rights Act 1996. |
To reply to you about the position you have applied for or inquired about. | The lawful basis we shall be relying on is the legitimate interest of the Data Controller in accordance with UK GDPR Article 6.1(f). |
To approach you as a good fit for employment, work experience or internship. | |
To move your application forward including making changes in applicant tracking systems or dedicated recruitment-based software and websites, or with agencies. | |
To inform you about the status of your application. | |
To check you are the right candidate for the role. | |
To receive a reference from a sectoral relevant individual where they have gained permission from you to be introduced to us | |
To send you notifications for other job, work experience or internship vacancies. | |
To invite you to participate in relevant surveys, questionnaires, and/or employment polls regarding your recruitment experience so we can improve our processes. | |
With permission, retain your personal information for longer statutory requirements where you have not been successful but would like the opportunity to invite you to apply again in the future. | The consent you have provided us for this use of your personal data in accordance with UK GDPR Article 6.1(a). |
To identify personal data and take relevant action upon submission of a data subject rights request. | Compliance with a legal obligation under UK GDPR Article 6.1(c). The legal obligation is the UK General Data Protection Regulation to uphold your data protection rights. Special categories of personal data used for the purpose stated will be under UK GDPR Article 9.2(g). |
We maintain a reserve list of candidates who met our requirements but were not successful in securing the specific post they applied for. We’ll ask for your permission to be added to this list. We will refer to the list when other roles are advertised and will contact you if you match the role. We will ask for your permission before putting you forward for the role.
If you are successfully recruited, we will upload your details to our HR system. We will also share your data for statistical analysis (it will be anonymised first) if we are required to do so by law – for example, by court order, or to prevent fraud or other crime.
For the purposes of reporting on and improving the effectiveness and efficiency of our recruitment systems and processes, we may retain a handful of personal data points about you (the source of your application, the stage you reached in the process, and the overall reason you were rejected), however, none of these data points are personally traceable to you.
When we carry out National Security vetting for some roles, we have to process personal data to perform a task that’s is of a substantial public interest depending on the sensitivity of the role.
If we offer you the opportunity to participate in our optional recruiting programs or if we collect sensitive personal data for legally permitted purposes other than compliance with our legal obligations regarding public health and workplace safety, we will ask for consent from you where you are not successful.
If you have interacted with Labour in a different way and if you expected to see something different to the list above, you can access all of our privacy notices by clicking here. If it is still not there, feel free to get in touch as mentioned below.
Who do we share your personal data with?
Any data shared with the below categories of recipients is the minimum necessary for the task they have been instructed to carry out on our behalf or in conjunction with us. Each category of recipient is subject to review by the Data Protection Team to make sure they have the right methods in place for keeping your personal data secure.
Where the sharing of personal data is within the context of a product or service being supplied under contract to Labour, a Data Processing Agreement, in accordance with GDPR Article 28 is put in place. This makes sure the supplier cannot use your personal data outside of the list of uses above.
Within the purposes of using your personal data, as listed above, we will share your personal data with the following:
- Pre-approved digital Human Resources Management platform provider;
- Pre-approved digital communications and storage providers;
- Pre-approved online survey/web-form platform providers; and
- Only if relevant to the role, local Labour Party organisations, Labour Candidates hoping to be elected, Labour Councillors, Labour Mayors and Labour Members of Parliament (MPs).
Please be reassured that Labour limits access to your recruitment personal data to those who have a genuine need to access it, including:
- The HR/people team;
- The recruiting manager for the role in question;
- Interviewers/assessment reviewers for the role in question;
- The director of the team where the role in question sits; and
- Other approvals managers or reviewers including internal or external auditors conducting an audit or investigation of our processes.
There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies, regulatory bodies or public authorities in order to prevent or detect crime, or prove we have adhered to their request. We will only ever disclose your personal data to these third parties to the extent we are required to do so by law.
Data sharing with a third-party organisation that is not a supplier of a product or service to Labour does not occur unless there is a legal obligation or sound lawful purpose for such sharing. For any such sharing we put a Data Sharing Agreement in place between Labour and the third-party containing specific information in accordance with the Information Commissioner’s Office ‘Data sharing code of practice’.
You can find further information on how local Labour Party organisations, Labour Candidates hoping to be elected, Labour Councillors, Labour Mayors and Labour Members of Parliament (MPs) use your personal data on their respective websites and more generally within our list of privacy notices which can be accessed by clicking here.
In all circumstances, the unlawful and unauthorised sharing of copies of personal data in which the Labour Party is the data controller is expressly prohibited. Any unauthorised sharing of Labour Party data is classified as a data breach which we will record and report to the ICO as required.
How long will we keep your personal data?
We will only keep personal information for as long as it is needed to fulfil the purpose for which it was collected.
We will store your information for the duration of the recruitment process. Where you have not been successful, we shall retain your personal data for up to 6 months in accordance with the UK Limitation Act 1980. We will only retain your personal data longer than 6 months where we have gained your permission to do so.
If you have been successful in the recruitment process, we will provide you with an Employee Privacy Notice outlining the retention period of your personal information.
What are your rights and how can you express them?
To understand your data privacy rights and to submit a rights request, the best way to do so is by visiting the ‘YOUR RIGHTS’ page on our website which you can get to by clicking here.
How can you complain about our use your personal data?
The best way to make a complaint is by visiting our page on ‘HOW TO MAKE A DATA PROTECTION COMPLAINT’ which you can access by clicking here.
How can you contact us about this privacy notice?
If you have any questions about the information in this privacy notice, then you can contact the Data Protection Team via email using [email protected] or by post within a letter to:
Labour Statutory Data Protection Officer
The Labour Party, Southworks, 20 Rushworth Street, United Kingdom, SE1 0SS
When was this privacy notice last updated?
We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify you of the changes where required by applicable law to do so.