Recruitment Privacy Notice

Introduction

We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. It is important that you read all of this Notice carefully as it sets out how Oodle Financial Service Limited (“Oodle”, “we” or “us”) handles your personal information when you apply for a job or other role with us and the rights you have in connection with that information. The term “applicants” is used in this Notice to refer to anyone who applies for a job role, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).

This notice explains what personal information we will hold about you, how we collect it, and how we will use and may share information about you.

Who collects the information

When you apply for a job with us, the personal data contained in your application will be collected by the Controller at Oodle Financial Services, which is located at Fletcher House, Oxford Science Park, Oxford OX4 4GE and can be contacted by emailing info@oodlefinance.com. The Controller’s data protection officer can be contacted at legal@oodlefinance.com

About the information we collect and hold

Part A of the Schedule below summarises the information we collect and hold up to and including the shortlisting stage of the recruitment process, how and why we do so, how we use it and with whom it may be shared.

Part B of the Schedule below summarises the additional information we collect before making a final decision to recruit, i.e. before making an offer of employment, how and why we do so, how we use it and with whom it may be shared.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

As a general rule, during the recruitment process, we do not collect or process any information that reveals your racial or ethnic origin, religion, political or philosophical beliefs, trade union membership, genetic data, biometric data or information concerning your health/sex life (“Sensitive Personal Information”), unless authorised by law or where necessary to comply with applicable laws.  However, in some circumstances, we may need to collect, or request some Sensitive Personal Information for legitimate recruitment-related purposes; for example, information about your physical or mental condition to consider accommodations for the recruitment process and/or subsequent job role. You may provide, on a voluntary basis, other Sensitive Personal Information during the recruitment process.

Purposes for processing personal information

We collect and use this personal information primarily for recruitment purposes – in particular, to determine your suitability for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying our reference checks or background checks (where applicable) and to generally manage the hiring process and communicate with you about it.

How long we keep your information

We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.

We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which it will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised, and the longer period for which they will be kept.

If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment.

Further details on our approach to information retention and destruction are available from our Recruitment Team, which can be reached at careers@oodlefinance.com

Who we share your information with and transfers abroad

We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of the information is maintained.

Transfers to other group companies

We will share your personal information with other companies in the Oodle group in order to administer our recruitment processes and store data.

Transfers to third party service providers

We may make certain personal information available to third parties who provide services relating to the recruitment process to us, including:

• recruitment or executive search agencies involved in your recruitment;
• background checking or other screening providers and relevant local criminal records checking agencies, e.g. Experian, CIFAS and/or JUMIO;
• data storage, shared services and recruitment platform providers, IT developers and support providers and providers of hosting services in relation to our careers website, e.g. Greenhouse and NaturalHR;
• third parties who provide support and advice including in relation to legal, financial/audit, management consultancy, insurance, health and safety, security, whistleblowing and reporting issues.

We may also disclose personal information to third parties on other lawful grounds, including:

• Where you have provided your consent;
• To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant;
• In response to lawful requests by public authorities (including for tax, immigration, health and safety, national security or law enforcement purposes);
• As necessary to establish, exercise or defend against potential, threatened or actual legal claims;
• Where necessary to protect your vital interests or those of another person; and/or
• In connection with the sale, assignment or other transfer of all or part of our business.

In some cases, the sharing described above may result in your personal information being transferred internationally, including countries outside of the European Economic Area, for example the United States of America. These countries may have data protection laws that are different to the laws in this country (and, in some cases, may not be as protective).

We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Notice.

Your rights to correct and access your information and to ask for it to be erased

You may exercise the rights available to you under applicable data protection laws as follows:

• If you wish to access, correct, update or request deletion of your personal information.
• You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
• If we have collected and process your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You can exercise these rights by contacting us using the contact details provided below.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

Further Information

For further information regarding this notice, to make a query or voice concerns, please contact our Data Protection Officer at legal@oodlefinance.com

How to complain

We hope that our Recruitment team or Data Protection Officer can resolve any query or concern you raise about our use of your information. If not, you may contact the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint. 

Schedule – About the information we collect and hold

Part A – Up to including the shortlisting stage

The information we collect

Identification data and contact details

i.e. address, home and mobile phone numbers, email address

How we collect the information:

• From You

Why we collect the information:

• Legitimate interest: to carry out a fair recruitment process.
• Legitimate interest: to progress your application, arrange interviews and inform you of the outcome at all stages.

How we use and may share the information:

• To enable HR personnel or the hiring manager of the relevant department to contact you to progress your application, arrange interviews and inform you of the outcome
• To inform the relevant manager or department of your application

Details of your qualifications, experience, employment history and interests

Including job titles salary and working hours

How we collect the information:

• From you, in the completed application form, c.v. (resume) and interview notes (if relevant)

Why we collect the information:

• Legitimate interest: to carry out a fair recruitment process.
• Legitimate interest: to make an informed decision to shortlist for interview and (if relevant) to recruit.

How we use and may share the information:

• To make an informed recruitment decision.
• The person making the shortlisting decision will receive non-anonymised details

Details of your nominated referees

Including their name, contact details, employer and job role

How we collect the information:

• From you, in the completed application form, c.v. (resume) and interview notes (if relevant)

Why we collect the information:

• Legitimate interest: to carry out a fair recruitment process in the regulated sector
• Legitimate interest: to comply with our legal obligations to obtain regulatory references (if relevant)

How we use and may share the information:

• To carry out a fair recruitment process
• To comply with legal/regulatory obligations Information shared with relevant managers, HR personnel

Other information you voluntarily provide, or we obtained from publicly available sources

e.g. LinkedIn, Facebook

How we collect the information:

• From you, in the completed application form, c.v. (resume) and interview notes (if relevant)
• From our research on publicly available information about you.

Why we collect the information:

• Legitimate interest: to carry out a fair recruitment process

How we use and may share the information:

• To carry out a fair recruitment process

Part B – Before making a final decision to recruit

The information we collect

Information about your previous academic and/or employment history

Including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers.

How we collect the information:

• From your referees (details of whom you will have provided)

Why we collect the information:

• Legitimate interest: to make an informed decision to recruit.
• Legitimate interest: to comply with our legal obligations.
• Legitimate interest: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice.

How we use and may share the information:

• To obtain the relevant reference about you.
• To comply with legal/regulatory obligations
• Information shared with relevant managers and HR personnel.

Information regarding your academic and professional qualifications

How we collect the information:

• From you
• From your education provider
• From the relevant professional body

Why we collect the information:

• Legitimate interest: to verify the qualifications information provided by you

How we use and may share the information:

• To make an informed recruitment decision

Information regarding your criminal record and your credit records

Including criminal records certificates (CRCs) and enhanced criminal records certificates (ECRCs)

Further details on how we handle sensitive personal information and information relating to criminal convictions and offences as required under the Data Protection Bill are set out in our Data Protection, Criminal Records Information and associated policies. The policies are available via request from our Recruitment Team.

How we collect the information:

• From you
• From the Disclosure and Barring Service (DBS)
• From Cifas
• From Experian

Why we collect the information:

• Legitimate interest: to perform the employment contract to comply with our legal obligations.
• Legitimate interest: to verify the criminal records information provided by you for reasons of substantial public interest (preventing or detecting unlawful acts and protecting the public against dishonesty)

How we use and may share the information:

• To make an informed recruitment decision.
• To carry out statutory checks Information shared with DBS, Cifas and other regulatory authorities as required.