ABOUT THIS POLICY
1. DURING THE COURSE OF OUR ACTIVITIES WE WILL PROCESS PERSONAL DATA (WHICH MAY BE HELD ON PAPER, ELECTRONICALLY, OR OTHERWISE) ABOUT OUR CUSTOMERS AND WE RECOGNISE THE NEED TO TREAT IT IN AN APPROPRIATE AND LAWFUL MANNER, IN ACCORDANCE WITH THE GENERAL DATA PROTECTION REGULATION (GDPR). THE PURPOSE OF THIS POLICY IS TO MAKE YOU AWARE OF HOW WE WILL HANDLE YOUR PERSONAL DATA.
2. HOWEVER DATA TECHNOLOGY AND RULES CHANGE REGULARLY, SO WE RESERVE THE RIGHT TO AMEND IT AT ANY TIME.
1. DATA PROTECTION PRINCIPLES
1. WE WILL COMPLY WITH THE SEVEN DATA PROTECTION PRINCIPLES IN THE GDPR, WHICH SAY THAT PERSONAL DATA MUST BE:
- PROCESSED FAIRLY AND LAWFULLY.
- PROCESSED FOR LIMITED PURPOSES AND IN AN APPROPRIATE WAY.
- ADEQUATE, RELEVANT AND NOT EXCESSIVE FOR THE PURPOSE.
- NOT KEPT LONGER THAN NECESSARY FOR THE PURPOSE.
- PROCESSED IN LINE WITH INDIVIDUALS’ RIGHTS.
- BE KEPT SECURE.
2. “PERSONAL DATA” MEANS RECORDED INFORMATION WE HOLD ABOUT YOU FROM WHICH YOU CAN BE IDENTIFIED. IT MAY INCLUDE YOUR CONTACT DETAILS, OTHER PERSONAL INFORMATION, PHOTOGRAPHS, EXPRESSIONS OF OPINION ABOUT YOU OR INDICATIONS AS TO OUR INTENTIONS ABOUT YOU. “PROCESSING” MEANS DOING ANYTHING WITH THE DATA, SUCH AS ACCESSING, DISCLOSING, DESTROYING OR USING THE DATA IN ANY WAY.
2. HOW WE ARE LIKELY TO USE YOUR PERSONAL DATA
1. WE WILL USUALLY ONLY PROCESS YOUR PERSONAL DATA WHERE YOU HAVE GIVEN US YOUR EXPLICIT CONSENT, FOR EXAMPLE TO REGISTER FOR ACCESS TO OUR WEBSITE, OR FOR ENTRY INTO A PRIZE PROMOTION, OR WHERE THE PROCESSING IS NECESSARY TO COMPLY WITH OUR LEGAL OBLIGATIONS. IN OTHER CASES, PROCESSING MAY BE NECESSARY FOR THE PROTECTION OF YOUR VITAL INTERESTS, FOR OUR LEGITIMATE INTERESTS OR THE LEGITIMATE INTERESTS OF OTHERS. THE FULL LIST OF CONDITIONS IS SET OUT IN THE GDPR.
- WE WILL ONLY PROCESS YOUR PERSONAL DATA FOR THE SPECIFIC PURPOSE OR PURPOSES NOTIFIED TO YOU OR FOR ANY OTHER PURPOSES SPECIFICALLY PERMITTED BY THE GDPR.
- YOUR PERSONAL DATA WILL ONLY BE PROCESSED TO THE EXTENT THAT IT IS NECESSARY FOR THE SPECIFIC PURPOSES NOTIFIED TO YOU.
- WE WILL SEEK TO KEEP THE PERSONAL DATA WE STORE ABOUT YOU ACCURATE AND UP TO DATE. DATA THAT IS INACCURATE OR OUT OF DATE WILL BE DELETED. HOWEVER, IT IS YOUR OBLIGATION TO KEEP US INFORMED OF ANY CHANGES TO YOUR PERSONAL DATA, EG. IF YOU MOVE HOUSE, OR IF YOU BECOME AWARE OF ANY INACCURACIES IN THE PERSONAL DATA WE HOLD ABOUT YOU. YOU MAY DO THIS BY SENDING AN EMAIL AS INDICATED IN SECTION FIVE.
- WE WILL NOT KEEP YOUR PERSONAL DATA FOR LONGER THAN IS NECESSARY FOR THE PURPOSE. THIS MEANS THAT DATA WILL BE DESTROYED OR ERASED FROM OUR SYSTEMS WHEN IT IS NO LONGER REQUIRED, WHICH IS TYPICALLY TWO YEARS FROM YOUR LAST INTERACTION WITH US, BY EMAIL, WEBSITE OR OTHER MEANS.
- WE WILL ONLY PROCESS YOUR DATA IN LINE WITH YOUR DATA RIGHTS.
2. YOU HAVE THE RIGHT TO:
- REQUEST ACCESS TO ANY PERSONAL DATA WE HOLD ABOUT YOU.
- PREVENT THE PROCESSING OF YOUR DATA FOR DIRECT-MARKETING PURPOSES.
- ASK TO HAVE INACCURATE DATA HELD ABOUT YOU AMENDED.
- PREVENT PROCESSING THAT IS LIKELY TO CAUSE UNWARRANTED SUBSTANTIAL DAMAGE OR DISTRESS TO YOU OR ANYONE ELSE.
- OBJECT TO ANY DECISION THAT SIGNIFICANTLY AFFECTS YOU BEING TAKEN SOLELY BY A COMPUTER OR OTHER AUTOMATED PROCESS.
3. TO EXERCISE ANY OF THESE RIGHTS, PLEASE SEND US AN EMAIL TO THE CONTACT IN SECTION FIVE WITH YOUR FULL NAME AND DETAILS AND WE WILL DO OUR BEST TO MAKE THE AMENDMENTS AS SOON AS POSSIBLE. BUT DO PLEASE UNDERSTAND THAT CHANGES MAY NOT BE IMMEDIATE.
4. WE WILL ENSURE THAT APPROPRIATE MEASURES ARE TAKEN AGAINST UNLAWFUL OR UNAUTHORISED PROCESSING OF PERSONAL DATA, AND AGAINST THE ACCIDENTAL LOSS OF, OR DAMAGE TO, PERSONAL DATA
5. WE WILL ENSURE THAT WE HAVE IN PLACE PROCEDURES AND TECHNOLOGIES TO MAINTAIN THE SECURITY OF ALL PERSONAL DATA FROM THE POINT OF COLLECTION TO THE POINT OF DELETION.
3. PROVIDING INFORMATION TO THIRD PARTIES
1. UNLESS WE HAVE OBTAINED YOUR SPECIFIC CONSENT, WE WILL NEVER TRANSFER YOUR DATA TO THIRD PARTIES FOR THEM TO COMMUNICATE DIRECTLY WITH YOU. THE ONLY EXCEPTION IS WHERE IT IS NECESSARY TO FULFIL OUR OBLIGATIONS TO YOU, FOR EXAMPLE TO GIVE A FULFILMENT COMPANY YOUR ADDRESS TO SEND YOU A PRIZE. BUT WE WILL ONLY TRANSFER PERSONAL DATA IF THE OTHER COMPANY AGREES TO COMPLY WITH OUR DATA PROCEDURES AND POLICIES, AND IF THEY PUT IN PLACE ADEQUATE DATA SECURITY MEASURES.
4. SUBJECT ACCESS REQUESTS
1. IF YOU WISH TO KNOW WHAT PERSONAL DATA WE HOLD ABOUT YOU, YOU MAY MAKE A REQUEST IN WRITING. SEND ALL SUCH REQUESTS TO THE ADDRESS IN SECTION FIVE.
5. DATA CONTACTS
1. FOR EMAIL REQUESTS: INFO@GROWUP.ORG.UK
2. FOR WRITTEN REQUESTS: GROWUP, RISE LONDON, 41 LUKE STREET, LONDON, EC2 4DP
3. FULL ADDRESS OF THE DATA CONTROLLER: GROWUP, RISE LONDON, 41 LUKE STREET, LONDON, EC2 4DP
6. ABOUT THIS POLICY
THIS POLICY WAS WRITTEN AND APPROVED ON DECEMBER 18TH 2020. ANY AMENDMENTS WILL BE AVAILABLE ON THIS PAGE.
CANDIDATE PRIVACY NOTICE
What is the purpose of this notice?
GrowUp Farms Limited is a “controller” in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR).
Data protection principles
We will comply with data protection law and principles, which means that your data will 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:
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter.
- The information you have provided on our application form, including any photo you upload to our applicant tracking system – Workable, or HR system – BambooHR, including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications.
- Any information you provide to us during an interview or at any stage of the recruitment process.
We may also collect, store and use the following types of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation, and political opinions.
- Information about your disability or health status
- Information about criminal convictions and offences.
For successful candidates who are offered a position
- As part of the recruitment process, if you are successful and offered a position the following additional data will be collected as part of your onboarding process before your start date:
- You will be required to undergo a right to work check, via TrustID, and we will store a copy of this right to work check on our HR system, BambooHR, under your future employee record.
- You will also be required to undertake a medical questionnaire as part of our occupational health assessment, via Innovate Healthcare, and a copy of this will be stored under your future employee record on our HR system, BambooHR.
- You will also be required to share your bank details of the account you would like your salary to be paid into ahead of your first day, so we can set you up on our Payroll. You will share these details onto our HR system, BambooHR directly. These will then be shared securely with our payroll service providers.
How is your personal information collected?
We collect personal information about candidates from the following sources:
- You, the candidate.
- Recruitment agencies.
- Right to work check, via the provider TrustID, which we collect the following categories of data: Passport/Visa documentation and/or driving licence.
- Occupational health data, via the provider Innovate Healthcare, from which you will be sent a questionnaire to complete which asks for details of your current/prior medical history.
- Disclosure and Barring Service, in respect of criminal convictions, via the provider Complete Background Screening, who will send you an application form to complete.
- Your named referees, from whom we request them to confirm your dates of employment, previous job role & responsibilities, character reference, and details of any prior disciplinary records.
- Data from third parties if it is from a publicly accessible source, such as LinkedIn.
How we will use information about you
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the work.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
It is also in our legitimate interests to decide whether to appoint you to the work since it would be beneficial to our business to appoint someone to that work.
We also need to process your personal information to decide whether to enter into a contract of employment with you.
Having received your job application we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the work. If we decide to offer you the work, we will then take up references (and any other checks we may be required to complete) before confirming your appointment.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
- We will use information about your health or disability status, if you choose to provide it, to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during interview or at any other part of the recruitment process. If you are offered a role at GrowUp Farms, we will also use the information collected about your health in our occupational health questionnaire, to inform whether we need to put in place any reasonable adjustments for when you start with us in your role.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
We do not envisage that we will process information about criminal convictions.
In the event that we are required to hold information about criminal convictions history, and if we would like to offer you the work (conditional on checks and any other conditions, such as references, being satisfactory), where permitted by law and otherwise if the role requires a higher degree of trust, we will then carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application:
- Our applicant tracking system, Workable, and if you are successful and offered a role, your data will be moved to our HR System as part of your onboarding: BambooHR.
- If you accept an offer of employment from GrowUp Farms, you will be asked to undertake a right to work check with TrustID, an occupational health questionnaire via Innovate Health, and you may be asked to undergo a DBS check, via Complete Background Screening. You will also be asked to provide your bank details for Payroll purposes, which will be shared securely with our payroll service providers.
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.
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.
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 will you use my information for?
We will retain your personal information for a period of six months after we have communicated to you our decision about whether to appoint you to the role. 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 your personal information in accordance with applicable laws and regulations.
During this six month period, whilst your personal information remains on file, we may consider you for other job opportunities which may arise in the future.
If we wish to retain your personal information for a longer period than six months, for another job opportunity in the near future that we wish to consider you for, we will write to you separately, seeking your consent to retain your personal information for a further period of time on that basis.
Rights of access, correction, erasure, and restriction
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- 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.
- Request erasure of your personal information. 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 object to processing (see below).
- Object to processing of 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.
- 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 the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact firstname.lastname@example.org in writing.
Right to withdraw consent
If at any stage of the recruitment process, your consent is sought to process your personal data, you have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
If you have any questions about this privacy notice or how we handle your personal information, please contact firstname.lastname@example.org. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) who is responsible for data protection issues in the UK.