Privacy Notice - General Data Protection Regulation (GDPR) For Candidates
What is the purpose of this document?
Wolverhampton Wanderers Football Club (1986) Limited (the Club) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are committed to protecting the privacy and security of your personal information and we are required under data protection legislation to notify you of the information contained in this privacy notice.
We have appointed Matt Wild, Club Secretary as data protection officer (the DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at DPO@wolves.co.uk. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
This notice applies to candidates for roles with the Club (regardless of whether they are successful or not). It makes you aware of 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. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with data protection principles which say that the personal information we hold about you must 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.
The kind of information we hold about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.
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;
- The information you have provided on our application form including personal details such as name, title, date of birth, gender, employment history and qualifications, next of kin, emergency contact information;
- Contact details such as addresses, telephone numbers, and personal email addresses;
- Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process);
- Any information you provide to us during an interview; and
- CCTV footage, log access control and visitor books.
We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about your race or ethnicity, religion or belief, sexual orientation, political opinions.
- Information about your health, including any medical condition, disability and medical, sickness or health details.
- CCJ, bankruptcy and insolvency checks.
- Information about criminal convictions and offences.
How is your personal information collected?
We typically collect personal information about candidates either directly from candidates or from third parties including former employers, credit reference agencies, other background check agencies, recruitment agencies, disclosure and barring service in respect of criminal convictions, your named referees and from third parties which is publicly accessible such as LinkedIn.
How we will use personal information about you
We will only use your personal information when the law allows us to. This includes but is not limited to the following grounds:
- Where we need to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest or for official purposes.
Examples of how we will process your personal information in accordance with the above grounds are listed below. However, some of the grounds will overlap and there may be several grounds which justify our use of your personal information.
- Making a decision about your recruitment or appointment.
- Assessing your skills, qualifications and suitability for a particular job or task, including decisions about promotions.
- Communicate with you about the recruitment process.
- Checking you are legally entitled to work in the UK.
- Complying with health and safety obligations.
- Carry out background and reference checks where applicable.
- Determining the terms on which you work for us.
- Comply with legal or regulatory requirements.
- Dealing with legal disputes involving you, or other candidates, employees, workers and contractors.
- To prevent fraud.
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
- Equal opportunities monitoring.
It is in our legitimate interests to decide whether to appoint you to work since it would be beneficial to our business to appoint someone to that work. We also need to process your personal information to decide whether to enter into a contract with you.
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 work. If we decide to offer you the work, we will then take up references and/or carry out a criminal record and/or carry out a credit check before confirming your appointment.
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 successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information about you
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following grounds:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations and in line with our data protection policy or exercise rights in connection with employment.
- Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme, and in line with our data protection policy.
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
- Where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
- 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 an 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.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in accordance with employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations. We may also use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We will collect information about your criminal convictions history if we would like to offer you the work (conditional on checks and any other conditions, such as references, being satisfactory). We are required to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular we are legally required by Financial Conduct Authority to carry out criminal record checks for those carrying out certain work.
We are allowed to use your personal information in this way to carry out our obligations.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you 21 days to request a reconsideration.
- Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law.
Sharing your information with third parties and other group entities
We will only share your personal information with the following third parties for the purposes of processing your application:
- W.W (1990) Limited – CV's of applicants for certain roles may be sent to the Club’s parent company.
- We may use recruitment agencies from time to time.
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.
Transferring information outside the EU
We will transfer the personal information we collect about you to countries outside the EU in order to perform our contract with you. There will not be an adequacy decision by the European Commission in respect of all of those countries. This means some of the countries to which we transfer your data are not deemed to provide an adequate level of protection for your personal information. However, we as data controller, are under an obligation to ensure that such transfers are performed in a manner that ensures that your personal information is adequately protected.
Therefore to ensure that your personal information does receive an adequate level of protection we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.
If you require further information about these protective measures, you can request it from the DPO.
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.
We will retain your personal information for a period of six 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 candidates 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 applicable laws and regulations.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of access, correction, erasure and restriction
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 (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, also known as data portability.
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 DPO in writing.
You will not 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 the DPO. 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.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact our Data Protection Officer Matt Wild at DPO@wolves.co.uk.