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Candidate Privacy Notice
Brightwell[1] are registered at One America Square, 17 Crosswall, London, England, EC3N 2LB (“we”, “us” or “our”) and are data controllers for any relevant Data Protection Regulations, including EU GDPR, UK GDPR and DPA 2018). We are committed to protecting and respecting your privacy.
This Privacy Notice sets out the basis on which we will process any personal data we collect from you, or that you or third parties provide to us, in connection with your membership in the Scheme and which relates to you or to any individual connected with you.
Please read this Privacy Notice (“Notice”) carefully so that you understand your rights in relation to your personal data, and how we will collect, use, and process your personal data.
In a situation where you provide us with your personal data to share with a third party who will provide a service to you directly, they are the data controller of that personal data and you are strongly advised to review their own privacy notice for details as to how they handle your personal data.
This Notice explains our policy in relation to:
We will receive the following information about you either directly from you or from third parties in connection with your application, such as recruiters, referees, and organisations that provide background checks:
We process your information as follows:
The information that we collect from you will only be processed within European Economic Area
(“EEA”).
We share your information with selected recipients. These categories of recipients include:
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through electronic means to us; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and Organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification.
We will retain your information as follows:
Successful Candidates: 6 years after employment ceases
Unsuccessful Candidates: At least 3 months but no longer than 12 months (unless applicants are notified, or records are required to defend an action)
Right to work and Background check report: At least 3 months but no longer than 12 months after employment ceases.
Your information will be retained for longer if required by law or a court order and/or as needed to defend or pursue legal claims.
You have certain rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights.
Please note that we will require you to verify your identity before responding to any requests to exercise your rights by completing the attached Data Subject Access Request form. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please fill out the attached form and submit it insert DPQueries@BrightwellPensions.co.uk
Also note that you may exercise your right to restrict our processing of your personal data whilst we consider your request as described below. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. We will retain the personal data if there are valid grounds under law for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case.
Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defense of legal claims or for another’s protection). You may request that we stop processing and just store the personal data we hold about you where:
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at DPQueries@BrightwellPensions.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a complaint with a supervisory authority.
We may update this notice from time to time and we will supply updated to copies to those organisations that supply recruitment services to Brightwell.
If you have any questions or concerns about this notice, please contact us at:
E-mail: DPQueries@BrightwellPensions.com
or
Data Governance Officer
BT Pension Scheme Management Limited One America Square
17 Crosswall
London EC3N 2LB
If you believe that we have handled your data incorrectly you can contact the Information Commissioner’s Office directly.
Information Commissioner’s Office
Wycliffe House Water Lane Wilmslow SK9 5AF
www.ico.org.uk
[1] BTPS Group including BT Pension Scheme Management Limited and BT Pension Administration Limited trading as Brightwell. Registered in England and Wales (No. 05154287) Authorised and regulated by the Financial Conduct Authority (Firm Reference Number: 486368).
