Candidate Privacy Notice

Blue Light Card Ltd (Blue Light Card, we, our, us) respects your privacy and is committed to protecting your personal data.

This policy aims to give you information on how we collect and process your personal data when you apply, or make a speculative application, for a role at Blue Light Card (whether this a temporary, permanent or contractor role).

It is important that you read this privacy notice together with any other notice that we may provide you on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This policy supplements other notices but is not intended to override them.

Blue Light Card Ltd is the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO, using the contact details below:

Blue Light Card Ltd
Charnwood Edge Business Park, Syston Road, Leicester, LE7 4UZ
peopleteam@bluelightcard.co.uk

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

We keep our privacy notice under regular review. This notice was last updated in August 2023.

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 relationship with us.

Our sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our sites, we encourage you to read the privacy notice of every website you visit.

What personal data will we process?

In connection with your application for work with us, we may process the following types of personal data about you:

• Full name;

• Email address and mobile number;

• The information you have provided to us in your CV and/or covering letter;

• The information you have provided on our application form;

• The information you provide to us during an interview, which will be noted by your interviewer(s).

If you are offered a role with us, we may also process the following types of personal data about you:

• Copies of your identification documents (e.g., passport, driving licence);

• The results of any background checks we carry out on you (e.g., adverse credit checks, Disclosure and Barring Service (“DBS”) checks, occupational history checks);

• References provided by your named referee(s);

• Where, due to the nature of the role you are offered, you are required to undergo a Ministry of Defence (“MOD”) counter terrorism check, the result of this check i.e., ‘pass’ or ‘fail’ only.

We may also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. If we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

We use different methods to collect your personal data, including through:

• Direct interactions with you, the candidate, where you send us your CV, attend an interview, or correspond with us by post, phone, email or otherwise;

• Third party recruitment websites such as LinkedIn and Indeed, where you apply for a role we have advertised on that website;

• Recruitment agencies;

• Background check providers, such as Experian;

• DBS in respect of criminal convictions;

• MOD in respect of counter terrorism checks;

• Your named referee(s).

How will we use your personal data?

We have set out below a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity - To make a decision about your recruitment or appointment

Lawful basis for processing:

• Performance of a contract with you
• Legitimate interests (to recruit employees, workers, temporary staff, and contractors)

Purpose/Activity - To check you are legally entitled to work in the UK

Lawful basis for processing:

• Performance of a contract with you
• Compliance with a legal obligation

Purpose/Activity - To undertake appropriate background and reference checks

Lawful basis for processing:

• Performance of a contract with you
• Legitimate interests (to ensure that our employees, workers, temporary staff, and contractors are suitable to work with us)

Purpose/Activity - To enable the MOD to carry out counterterrorism checks, where required

Lawful basis for processing:

• Performance of a contract with you
• Legitimate interests (to ensure that our employees, workers, temporary staff, and contractors are suitable for a role in which they have access to certain types of highly sensitive personal data)

Purpose/Activity - To contact you about a vacancy we consider you are suitable for where you have made a speculative application

Lawful basis for processing:

• Legitimate interests (to recruit employees

Purpose/Activity - To deal with legal disputes involving you

Lawful basis for processing:

• Performance of a contract
• Compliance with a legal obligation

Purpose/Activity - To comply with our legal obligations

Lawful basis for processing:

• Compliance with a legal obligation

Do we use automated decision making?

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

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.

How do we share your personal data?

For the purposes set out above, we will share your information with the following third parties:

• Service providers acting as data processors on our behalf, including providers of software, candidate tracking tools, IT hosting or support;

• Our professional advisors, including our legal advisors, accountants, insurers, and auditors;

• Your named referee(s);

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We may also need to share your personal information with a regulator or to otherwise to comply with the law.

We may in some circumstances transfer your personal data outside the UK. Any such transfers of your data outside the UK will only be carried out if:

• The UK government has granted an adequacy decision for the country receiving the data, determining that the laws of that country provide essentially equivalent protection as those of the UK; or

• An appropriate safeguard in in place as required by the UK GDPR for transfers of data, for example using UK government approved standard contractual clauses.

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.

How long will we retain your data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you

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, regulatory, tax, accounting, or other requirements.

If we decide your application is unsuccessful, your personal data will be kept for 6 months following this decision, after which it will be securely deleted. During that period, we may use your personal data to consider whether you are suitable for one of our current or upcoming vacancies and may contact you about those vacancies

How do we secure your data?

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. Additionally, 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.

What are your rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us at the contact details set out above.

When we receive any request to access, edit or delete personal data we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

You have the right to:

• Request access to your personal data. 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 information 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;

• Where we are processing your data on the basis of consent, to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.

What if we change 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.