Travelopia Job Applicant Privacy Notice Policy

Data controller: Travelopia Holdings Limited, Origin 1, 108 High Street, Crawley, RH10 1BD

As part of our candidate application and recruitment process, Travelopia Holdings Limited collects, processes and stores personal information about you. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations. This notice and its contents applies to Travelopia Holdings limited and its associated companies.

This privacy notice describes how we collect and use personal information about you during and after your job application, in accordance with the General Data Protection Regulation (GDPR). Should we make, and you accept an offer of employment, then a fresh Privacy Notice will apply.

This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time. 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.

1. What information do we collect?

1.1 We collect a range of information about you. This includes:

the information you have provided to us in your curriculum vitae and covering letter or in our application form, including your name, address, contact details. (including email address and telephone number) date of birth, gender;

details of your academic and professional qualifications, skills, experience and employment history;

information about your current level of remuneration, including benefit entitlements;

any information you provide to us during an interview;

whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;

information about your entitlement to work in the UK; and

equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

1.2   We may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

1.3   We may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. We will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so.

1.4   Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

2.   Why do we process personal data?

2.1   We need to process data to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you.

2.2   In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts.

2.3   We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

2.4   We may process information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.

2.5   We may also process other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief for the purposes of equal opportunities monitoring. Data that we use for these purposes is anonymised or is collected with the express consent of job applicants, which can be withdrawn at any time. Job applicants are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

2.6   For some roles, we are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.

2.7   If your application is unsuccessful, we may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before we keep your data for this purpose and you are free to withdraw your consent at any time.

3.   Who has access to data?

3.1   Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

3.2   We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

3.3   We may transfer your personal data to countries outside the European Economic Area (EEA) in order to complete the recruitment process. In some cases, the data may be transferred to a country which has not been recognised by the European Commission to have adequate data protection standards. In these circumstances, we would take measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection. For example, we would implement standard contractual clauses or (where the third party is located in the U.S) we would rely upon the EU-U.S Privacy Shield.

4.   How do we protect data?

4.1 We take the security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the performance of their duties. Further details of the security measures in place are available upon request.

4.2 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.

5. For how long do we keep data?

5.1 If your application for employment is unsuccessful, we will hold your data on file for six months after the end of the relevant recruitment process. We retain your data 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. If you agree to allow us to keep your personal data on file, we will hold your data on file for a further six months for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, your data is deleted or destroyed.

5.2 If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

6. Your rights

6.1 As a data subject, you have a number of rights. Under certain circumstances, you can:

access and obtain a copy of your data on request;

require us to change incorrect or incomplete data;

require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;

object to the processing of your data where we are relying upon our legitimate interests as the legal ground for processing; and

request that we transfer your personal information to another party.

6.2   If you would like to exercise any of these rights, please contact Human Resources by email at HR@travelopia.com or by post at Travelopia Holdings Limited, Origin One, 108 High Street, Crawley, West Sussex, RH10 1BD.

6.3   If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner. However, we would always encourage you to contact us in the first instance.

7.   What if you do not provide personal data?

7.1 You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

8. Automated decision-making

8.1 During the recruitment process 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.