Applicant Privacy Notice

We are committed to protecting the privacy and security of your personal information and to being transparent about how we collect and use it.

Orangebox is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.

As part of any recruitment process, Orangebox collects and processes personal data relating to job applicants (whether this be as an employee, worker or contractor). The purpose of this Privacy Notice is to inform you how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation (GDPR). What are the data protection principles? What kind of information do we hold about you? How do we collect data about you? How do we use information about you? If you fail to provide personal information How do we use sensitive personal information? How do we use information about criminal convictions? Who has access to your data? Automated decision-making Data sharing with third parties What security measures do we take? How long will we use your information for? Your rights in connection with personal information Who do I contact for further information?

What are the data protection principles?

We will comply with data protection law and principles, which means that your data will be:

• Used lawfully, fairly and in a transparent way.

• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

• Relevant to the purposes we have told you about and limited only to those purposes.

• Accurate and kept up to date.

• Kept only as long as necessary for the purposes we have told you about.

• Kept securely.

What kind of information do we hold about you?

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

• The information you have provided to us in your curriculum vitae and covering letter, or application form. This includes your name, title, address, telephone number, personal email address, date of birth, gender, employment history, skills, qualifications, right to work information, current level of remuneration.

• Any information you provide to us during an interview.

We may also collect, store and use the following “special categories” of more sensitive personal information:

• Information about your race or ethnic origin, religious beliefs, sexual orientation.

• Information about your health, including any medical condition, disabilities, health and sickness records.

• Information about criminal convictions and offences.

How do we collect data about you?

We collect personal information about job applicants from the following sources:

• You, the job applicant, via CV's, letters, application forms, identity documents, interviews, or assessments.

• Any recruitment agency we use, from which we collect the following categories of data: those listed above in "What kind of information do we hold about you?"

• Disclosure and Barring Service in respect of criminal convictions (DBS) (only for specific roles where required).

• Once a job offer is made: your named referees, from whom we collect the following categories of data: confirmation of your previous employment history as far as the referee is aware.

How do we use information about you?

We will use the personal information we collect about you to:

• Communicate with you about the recruitment process.

• Assess your skills, qualifications, and suitability for the role.

• Carry out background and reference checks, where applicable.

• Keep records related to our recruitment processes to demonstrate a fair and transparent process.

• Comply with legal or regulatory requirements, including to check a successful applicants eligibility to work in the UK before employment starts.

• Decide whether to enter into a contract of employment with you.

It is in our legitimate interests to process personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer the job. We may also need to process data from job applicants to respond to and defend against legal claims.

Having received your CV and covering letter or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references upon your acceptance of our conditional offer of employment which will be subject to receipt of satisfactory references.

Where there are specific checks needed for your particular role, such as a basic Disclosure and Barring Service (DBS) check for Installation & Service Engineers, we will inform you in a separate notice.

If your application Is unsuccessful, we will keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application further.

How do we use sensitive personal information?

We will use sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.

• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

How do we use information about criminal convictions?

We do not (for most posts) envisage that we will process information about criminal convictions, however, it is possible that you may bring something to our attention within the information you provide as part of the application process.

If you are applying for a role in Installation & Service or Finance we may collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a basic disclosure check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular, Finance roles require a high degree of trust and integrity since it involves dealing with money and so we may ask you to seek a basic disclosure of your criminal records history.

If you are applying for a job as an Engineer you need to be aware that customers often require vetting to be done on those attending their premises to prevent Terrorism. If you are appointed to such a post, you will be asked to consent to searches into your background including a basic disclosure of your criminal records history.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Who has access to your data?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR team, recruiting managers, and any other member of staff involved in the interview stages.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing with third parties

We will only share your personal information with the following third parties for the purposes of processing your application: employment agencies. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What security measures do we take?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

How long will we use your information for?

We will retain your personal information for a period of 6 months after we have communicated to you our decision about whether to appoint you to work. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against job applicants on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.

If we wish to retain your personal information on file, 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 on that basis.

Your rights in connection with personal information

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 (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

• 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 data, or request that we transfer a copy of your personal information to another party, please contact the HR Department in writing.

Who do I contact for further information?

If you have any questions about this privacy notice or how we handle your personal information, please contact the HR Department.