Candidate Privacy Notice
WHAT IS THE PURPOSE OF THIS DOCUMENT?
The Royal Mint Limited, its group companies and its websites www.royalmint.com and www.royalmintbullion.com (“The Royal Mint”), is committed to protecting the privacy and security of your Personal Data.
The Royal Mint consists of the below listed companies.
Any Personal Data provided to, or gathered by, The Royal Mint Limited (this includes customers of www.royalmint.com and www.royalmintbullion.com) is controlled by The Royal Mint Limited incorporated and registered in England and Wales with company number 06964873 whose registered office is at Llantrisant, Pontyclun, Mid Glamorgan, South Wales, United Kingdom CF72 8YT.
Information Commissioner’s Office Registration Number: Z2075700.
VAT Registration Number: GB 256 5227 96.
Any Personal Data provided to, or gathered by, RM Assets Limited is controlled by RM Assets Limited incorporated and registered in England and Wales with company number 09058416 whose registered office is at Llantrisant, Pontyclun, Mid Glamorgan, South Wales, United Kingdom CF72 8YT.
Information Commissioner’s Office Registration Number: ZA320379.
Any Personal Data provided to, or gathered by, RM Experience Limited is controlled by RM Experience Limited incorporated and registered in England and Wales with company number 10953110 whose registered office is at Llantrisant, Pontyclun, Mid Glamorgan, South Wales, United Kingdom CF72 8YT.
Information Commissioner’s Office Registration Number: ZA324165.
This privacy notice describes how we collect and use Personal Data about you during and after the application and recruitment process, in accordance with the General Data Protection Regulation (GDPR).
The Royal Mint is a “data controller”. This means that we are responsible for deciding how we hold and use Personal Data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to candidates applying for opportunities to work at The Royal Mint or any of The Royal Mint group of companies.
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 Data about you, so that you are aware of how and why we are using such information.
This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
1 - DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the Personal Data we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
2 - THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal data, or Personal Data, 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 may collect, store, and use the following categories of Personal Data about you:
- Personal contact details such as name, title, 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).
- Employment records (including job titles, work history, working hours, training records and professional memberships).
- Your image (which may be recorded on CCTV) and your vehicle details and registration if you visit us for an interview.
We may also collect, store and use the following “special categories” of more sensitive Personal Data:
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
3 - HOW IS YOUR PERSONAL DATA COLLECTED?
We collect Personal Data about candidates through the application and recruitment process, either directly from candidates or sometimes from an employment agency. We may sometimes collect additional information from third parties including former employers, other background check agencies.
4 - HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
1. Where we need to comply with a legal obligation.
2. In limited circumstances, with your explicit written consent.
3. 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.
We may also use your Personal Data in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest.
- Situations in which we will use your Personal Data
We need all the categories of information in the list above (see The kind of information we hold about you) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your Personal Data to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your Personal Data are listed below.
- Providing job alerts by email (where you have applied to receive these)
- Making a decision about your recruitment or appointment.
- Determining the terms on which you work for us.
- Checking you are legally entitled to work in the UK.
- Administering the contract we have entered into with you.
- Assessing qualifications for a particular job or task.
- Ascertaining your fitness to work once an offer has been made.
- Complying with health and safety obligations.
- To prevent fraud and money laundering.
- Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your Personal Data.
- If you fail to provide Personal Data
If you fail to provide certain information when requested, we may not be able to make you an offer of employment or may have to withdraw an offer if it has already been made.
- Change of purpose
We will only use your Personal Data 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 Data 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 Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5 - HOW WE USE PARTICULARLY SENSITIVE PERSONAL DATA
”Special Categories” of particularly sensitive Personal Data require higher levels of protection. We need to have further justification for collecting, storing and using this type of Personal Data. We may process special categories of Personal Data in the following circumstances:
1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations and in line with our Data Protection Policy.
3. Where it is needed in the public interest and in line with our Data Protection Policy.
4. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
Less commonly, we may process this type of information 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 may also process such information about current and former employees, workers and contractors in the course of legitimate business activities with the appropriate safeguards.
- Our obligations as an employer
We will use your particularly sensitive Personal Data in the following ways:
We will use information about your disability status in order to make appropriate adjustments and to ensure health and safety in respect of the application and recruitment process.
After an offer has been made we will use information about your disability status, physical or mental health, to ensure your health and safety in the workplace and to assess your fitness to work, to assess and provide appropriate workplace adjustments.
- Do we need your consent?
We do not need your consent if we use special categories of your Personal Data in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of 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 and provided we do so in line with our Personnel Security Vetting and Data Protection Policy.
Less commonly, we may 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 envisage that we will hold information about criminal convictions.
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so.
We will usually use information about criminal convictions and offences in the following ways:
- When considering an offer of employment.
We use information about criminal convictions in order to maintain a safe and secure working environment, and to maintain the security of the site.
We only use information about criminal convictions where we have your explicit consent. We reserve the right to refuse to issue an offer of employment or may have to withdraw an offer of employment, where consent is refused.
6 - AUTOMATED DECISION-MAKING
Automated decision-making takes place when an electronic system uses Personal Data to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. 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 Data, 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.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
7 - DATA SHARING
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.
We will not transfer your information outside of the EU.
- Why might you share my Personal Data with third parties?
We do not sell, rent or otherwise trade your Personal Data with others. While most of our work is done by our employees who access your Personal Data directly from our systems which are under our direct control, we do use third-party service providers to perform certain functions on our behalf. We may also be required to share your Personal Data with third parties where required by law or where we have another legitimate interest in doing so. Please note that if we are requested by the police, government, regulatory, or other body investigating suspected illegal activities to provide your Personal Data, we are entitled to do so.
- Which third-party service providers process my Personal Data?
We have listed below examples of the kind of third-party service providers that we work with. We have also listed examples of the types of information that they may have access to and the reasons that we may need to share your Personal Data with them.
Professional Services would have access to your Personal Data including contact information. The purpose for this type of transfer being to ensure our compliance with our legal obligations (including anti-money laundering and counter-terrorist financing verification).
IT Support would have access to the Personal Data in our custody with which we require support. The purpose for this type of transfer being to resolve IT issues in order to administer the working relationship with you.
Data Storage would have access to all the Personal Data in our custody. The purpose for this type of transfer being to provide us with secure data storage and back-up.
- How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Data 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.
- When might you share my Personal Data with other entities in the group?
We will share your Personal Data with other entities in our group from time to time including as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
- What about other third parties?
We may share your Personal Data with other third parties, for example in the event of any future restructuring of the business. We may also need to share your Personal Data with a regulator or to otherwise comply with the law.
- Transferring information outside the EEA
We will not transfer your information outside of the EEA.
8 - DATA SECURITY
We have put in place measures to protect the security of your information. Details of these measures are outlined in the Information Security Policy.
Third parties will only process your Personal Data on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data 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.
9 - DATA RETENTION
- How long will you use my information for?
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Normally this will be for 6 months after a recruitment decision for unsuccessful candidates. However if you have signed up and created a candidate profile, we will retain your data for the duration that you hold a candidate profile and up to 12 months after you have closed this. You are able to create or delete job alerts at any time by signing into your candidate profile.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Once you are no longer a candidate of the company, and have not consented to us retaining your data to inform you of new opportunities, we will retain and securely destroy your Personal Data in accordance with our Data Retention Policy and also any applicable laws and regulations.
Personal Data for successful candidates will be transferred to their employee file, and held in accordance with our Data Retention Policy.
10 - RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
- Your duty to inform us of changes
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your working relationship with us.
- Your rights in connection with Personal Data
Under certain circumstances, by law you have the right to:
- Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data 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 Data. This enables you to ask us to delete or remove Personal Data 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 Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data 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 Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data to another party.
If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact the Data Protection Officer in writing.
- No fee usually required
You will not have to pay a fee to access your Personal Data (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.
- What we may need from you
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 Data is not disclosed to any person who has no right to receive it.
11 - RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data 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 Data Protection Officer. 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.
12 - DATA PROTECTION OFFICER
We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your Personal Data, please contact the DPO.
Mail: The Royal Mint, Llantrisant, Pontyclun, Mid Glamorgan, South Wales, United Kingdom CF72 8YT.
If you are dissatisfied with the handling of your Personal Data or how we have responded to a request to exercise your data subject rights, you have the right to ask for an internal review. An internal review will consider whether or not your Personal Data and/or request were handled appropriately, in line with applicable data protection laws and regulations.
Internal review requests should be submitted to the Data Protection Officer by using the contact information above. Internal reviews will be carried out by the Finance Director. We aim to respond within 20 working days of the receipt of the request for an internal review.
If you are dissatisfied with the outcome of the review, then you may seek a review by the Information Commissioner’s Office (ICO), which has the powers to uphold or overturn the decision. Please see ICO contact information below. The Royal Mint will abide by the decisions of the ICO, unless it considered itself to have grounds for an appeal to the First-Tier Tribunal (Information Rights).
Mail: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
13 - 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 Data.
Last Updated: 18/02/2019
If you have any questions about this privacy notice, please contact the Data Protection Officer.