Candidate Application Privacy Policy

This notice is intended to provide information regarding the use of your personal data by United Gas & Power Ltd (UGP) for the purposes of the application process. It has been updated to address changes introduced by the General Data Protection Regulation (“GDPR”) as implemented in the UK.

1. Who collects your information?

United Gas & Power Ltd, 16 Otley Road, Guiseley, LS20 8AH is the ‘data controller’ or ‘company’ of this processing activity.

2. Legal basis and process for processing your information

We process your personal data to manage our recruitment process, assess your suitability for employment, communicate with you, and make hiring decisions. We rely on one or more of the following lawful bases under the UK GDPR:

  • Legitimate interests (Article 6(1)(f)) – to recruit and select suitable candidates and to operate an efficient recruitment process;
  • Steps prior to entering into a contract (Article 6(1)(b)) – where processing is necessary to take steps at your request before entering into an employment contract;
  • Legal obligation (Article 6(1)(c)) – for example to carry out right to work checks; and
  • Consent (Article 6(1)(a)) – only where required and appropriate (you may withdraw consent at any time).

3. Who do we share the information with?

We may need to share some of the categories of personal information (detailed in 4. What information do we collect?) with other parties, such as our HR department, recruitment agencies, your referees, providers of profiling and psychometric tests, background and criminal records checks (where appropriate) and IT service providers.

Some of these are independent data controllers, with their own privacy notices explaining how and why they use your personal data. Others are our processors, with whom we have written agreements in accordance with data protection law. For more information, contact us at [email protected].

4. What information do we collect?

We receive information about you from a number of sources. We may also collect data from recruiters and recruiting agencies.

The information we receive and store up to and including the shortlisting stage may include as follows:

  • Your name and contact details (i.e. address, home and mobile phone numbers, email address)
  • Your curriculum vitae
  • Details of your qualifications, experience, employment history (including job titles potential salary level and working hours) and interests
  • Details of your referees

We may collect the following information after the shortlisting stage, and before making a final decision to recruit, to the extent permitted by law:

  • Information about your previous academic and/or employment history*
  • Information regarding your academic and professional qualifications*
  • Your nationality and immigration status and information from related documents, such as your passport and/or other identification and immigration information**
  • Where applicable, information regarding your criminal record, in criminal records certificates (CRCs) and enhanced criminal records certificates (ECRCs)*

The information marked “**” is required by law to enable us to verify your right to work.
The information marked “*” may be required by us to assess your suitability for the position.
If you do not provide it, we may not be able to take your application forward.

5. Special categories of data: sensitive and/or personal information

Where we process special category personal data (e.g., health/disability or ethnicity), we will only do so where permitted to by law and with appropriate safeguards in place.

This may include processing to meet our obligations and rights in connection with employment, and/or for equal opportunities monitoring. Equal opportunities information is used only for monitoring and reporting where possible and is not used in recruitment decision-making.

6. International Transfers

Some of our service providers may process personal data outside the UK. Where we transfer personal data outside the UK, we will ensure appropriate safeguards are in place, such as adequacy regulations or standard contractual clauses (including the UK International Data Transfer Agreement and/or the UK Addendum where applicable).

7. Where do we hold your information?

Information is stored in our Application System accessed via our website CMS, and accessed by the Company, and third-party agencies, service providers, representatives. It will then be held on UGP’s internal secure servers.

8. How long do we keep your information?

We will retain the personal information of unsuccessful candidates for a period of six months from the date we communicated to them our decision not to appoint them/take their application forward.

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 personal information in accordance with our data retention policy and applicable laws and regulations.

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

Please let us know if you have further questions regarding our retention of data.

To object to processing where we rely on legitimate interests, you can object to our processing of your personal data on grounds relating to your particular situation.

9. Your rights with respect to your personal information

In relation to the processing of your information by the Company, you have the following rights:

  • To request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • To 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.
  • To request erasure of your personal information, in certain circumstances. 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 withdraw consent (see below).
  • To 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 avoid the erasure of the personal data.
  • To request the transfer of your personal information that you have provided to us to another party, i.e. the right to data portability in certain circumstances, where you have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without hindrance from us.
  • Where we are relying on your consent, to withdraw your consent at any time. Please keep in mind that withdrawing your consent does not have retroactive effect. This means that the withdrawal does not affect the lawfulness of past processing based on consent before its withdrawal. The Company is therefore not required to undo this past processing following the withdrawal of your consent.
  • The right to complain to the relevant supervisory authority. This is the Information Commissioner’s Office (“ICO”) (www.ico.org.uk) (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us if you have a concern.

To object to processing where we rely on legitimate interests, you can object to our processing of your personal data on grounds relating to your particular situation.

If you wish to exercise your rights, issue a request, or if you have other questions, comments or concerns about our privacy practices, please contact [email protected].

10. Automate decision-making

We do not make recruitment decisions based solely on automated decision-making. If we use automated tools (for example, online assessments) we will provide you with information about how they are used and your rights.

11. Updates

We may update this notice periodically. Where we do this, we will inform you of the changes and the date on which the changes take effect.