DNAe Group Holdings Ltd (DNAe) is an employer based in White City, London

This privacy notice applies to all applicants that are not currently staff members of DNAe. If you are applying for a promotion or another job in the organisation and are already employed by DNAe, please refer to the privacy notice for staff.

What is the purpose of this document?

DNAe and its Group Companies are committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during the application and recruitment process with us, in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, and any applicable national laws, regulations and secondary legislation, as amended or updated from time to time.

DNAe will be your “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

You have been sent this privacy statement because you have applied for a position with us, so as to make you aware of how and why your personal data will be used during the recruitment process and afterwards.

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 information about you, so that you are aware of how and why we are using such information.

Data Protection Officer

We have appointed a Data Protection Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely

The kind of information we hold about you

Personal data, or personal information, means any information about you from which you can be identified. It does not include data where your identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

Examples of personal data will include:

• Contact details – name, title, address, email address(es), date of birth, phone number(s)
• Right to work documentation – passports, visas, national identity cards
• Gender
• Marital status and dependents
• Next of kin details – name, address, phone number and relationship
• National insurance number
• Copy of driving licence
• Details relating to education and training – degrees, qualifications, professional memberships
• Experience details – previous roles, working hours, training records, employers,references, CV, cover letter

We may also collect, store and use the following ‘special categories’ of more sensitive personal information:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your health, including any medical condition, health and sicknessrecords.
• Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about all applicants from the application and recruitment process, either directly from candidates or from an employment agency or background check provider. We may collect additional information from third parties including former employers, or other background check agencies.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need to comply with a legal obligation. This will include providing information to HMRC, responding to requests from courts, law enforcement agencies and other public and government authorities, ensuring that you are entitled to work in the UK and ongoing compliance with our health and safety obligations.
• 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. This will includemonitoring your use of our information and communication systems, and ensuringnetwork and information security, including preventing unauthorised access to ourcomputer and electronic communications systems and preventing malicious software distribution.

We may also use your personal information in the following situations, which are likely to be rare:

• Where we need to protect your interests (or someone else’s interests);
• Where it is needed in the public interest or for official purposes.

If you fail to provide certain information when requested, we may not be able to continue with the application process (such as confirming your right to work or obtaining references), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

We will only use your personal information for the purposes for which we have 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information will only be processed in accordance with the data protection legislation and in accordance with this privacy notice.

We may use information relating to your health for the purposes of considering matters relating to your health and safety in the workplace, to assess your fitness to work and to provide appropriate workplace adjustments.

We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation and disability status, to ensure meaningful equal opportunity monitoring and reporting and to comply with employment and other laws, for example if you raise concerns about the recruitment process which relate to a protected characteristic.

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights. 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. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

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. Where appropriate, we will collect information about criminal convictions as part of the recruitment process.

Automated decision-making

Automated decision-making takes place when an electronic system uses personalinformation to make a decision without human intervention. We are allowed to useautomated decision-making in the following circumstances:

• Where we have notified you of the decision and given you 21 days to request a reconsideration.
• Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
• In limited circumstances, with your explicit written consent and where appropriatemeasures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, 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.

Who we share your personal information with‍

We may share your data with any other entities in our group as part of our regular reporting activities or ongoing performance, or in relation to business planning.

We may have to share your data with third parties, including third party service providers, or where required by law, or in order to perform our obligations to you, or where we have another legitimate interest in doing so. “Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. This may include HMRC, and the Health & Safety Executive. We may also share personal information with our professional and legal advisers for the purposes of taking advice.

In the event that we do share personal information with external third parties, we will only share such personal information that is strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.

How we protect your personal information

Your personal information is stored on our paper and electronic filing systems and our servers based in the UK and is accessed by our staff for the purposes set out above.

Other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request. 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. In addition, 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. Details of these measures may be obtained from IT or HR.

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.

How long we keep your personal information

We will only keep your personal information for as long as necessary to comply with our obligations and to safeguard DNAe in the event of any claims, complaints, litigation,enquiries and investigations during or following the recruitment process. We will keep your personal information for a period of 12 months after we have communicated the recruitment decision to you, 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 your personal information.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

We will retain your data in line with the Information Commissioners Office guidance. 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 andwhether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your rights

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the application process with us.

You can exercise any of the following rights by writing to the HR Manager / Data Protection Officer, DNAe, Scale Space, 58 Wood Lane, London W12 7RZ or e-mailing human.resources@dnae.com.

Your rights in relation to your personal information are:

• You have a right to request access to the personal information that we hold about you by making a “subject access request”
• If you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we correct or complete your personal information
• You have a right to request that we restrict the processing of your personal information for specific purposes for example if you want us to establish its accuracy or the reason for processing it
• Object to processing your personal information 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
• You may request the transfer of your personal information to another party
• If you wish us to delete your personal information, you may request that we do so 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 object to processing.

You will not have to pay a fee to access your personal information (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.

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 information is not disclosed to any person who has no right to receive it.

In applying for a role with us, you are agreeing that we may process your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for such processing at any time. To withdraw your consent, please use the contact details above. 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.

Any requests received by DNAe will be considered under applicable data protection legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner’s Office at www.ico.org.uk.

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 information.

If you have any questions about this privacy notice, please contact HR Manager / Data Protection Officer.