This notice explains what personal data (information) the London Borough of Lambeth (the ‘Council’, ‘we’) will hold about you, outlining how we collect, and share information about you during the application process. The Council is required to notify you about this information under data protection legislation. Please ensure that you read this notice (formerly referred to as a privacy notice) and any other similar notice we may provide to you from time to time, when we collect or process personal information about you.
Who collects the information?
The London Borough of Lambeth (the "Council", "we") is a ‘data controller’ and gathers and uses certain information about you.
Data protection principles
The Council will comply with the Data Protection Act 2018 and GDPR regulation when gathering and using personal information, as set out in our data protection policy.
About the information we collect and hold
The table set out in Part 1 of Schedule 1 below summarises the information the Council collects and holds up to; including the shortlisting stage of the recruitment process, how and why we do so, how we use it and with whom it may be shared.
The table in Part 2 of Schedule 1 below summarises the additional information we collect before making a final decision to recruit, i.e. before making an offer of employment, how and why we do so, how we use it and with whom it may be shared.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
Where information may be held
Information may be held at our offices, and those of third-party agencies, service providers, representatives and other agents.
How long we keep your information
The Council will keep the personal information that it obtains about you during the recruitment process, for no longer than is necessary, for the purposes for which it is processed i.e., application, assessment, offer of employment. This will depend on whether your application is successful, and you become employed by the Council, the nature of the information concerned and the purposes for which it is processed.
The Council will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, the Council may do so, but will first consider whether the records can be pseudonymised and will establish a longer period for which they will be kept.
If your application is successful, the Council will keep only the recruitment information that is necessary in relation to your employment. For further information, see our data protection privacy notice (employment).
Further details on our approach to information retention and destruction are available in the Council's record retention policy.
Your right to object to us processing your information
Where the Council's processing of your information is based solely on the Council's legitimate interests (or those of a third party); you have the right to object to that processing if you give the Council specific reasons as to why you are objecting, which are based on your particular situation. If you object, the Council can no longer process your information unless it can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
Please contact the Council's Data Protection Officer (DPO), who can be contacted via email, infogov@lambeth.gov.uk or by telephone on 020 7926 7717, if you wish to object in this way.
Your rights to correct and access your information and to ask for it to be erased
Please contact the Council's DPO if (in accordance with applicable law) you would like to correct or request access to information that the Council holds relating to you or if you have any questions about this notice. You also have the right to ask the DPO for some, but not all, of the information we hold and process to be erased (this is the ‘right to be forgotten’) in certain circumstances. The DPO will provide you with further information about the right to be forgotten, if you ask for it.
Keeping your personal information secure
The Council has appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. The Council limits access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
The Council also has procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that the Council's DPO can resolve any query or concern you raise about our use of your information. If not, you can contact the Information Commissioner or telephone 0303 123 1113 for further information about your rights and how to make a formal complaint.
Schedule 1 About the information we collect and hold
Part 1 Up to and including the shortlisting stage
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The information the Council collects
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How the Council collects the information
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Why the Council collects the information
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How the Council uses and may share the information
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Your name and contact details (i.e. address, home and mobile phone numbers, email address)
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From you
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Legitimate interest: to carry out a fair recruitment process.
Legitimate interest: to progress your application, arrange interviews and inform you of the outcome at all stages.
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To enable HR personnel and/or the manager of the relevant department to contact you to progress your application, arrange interviews and inform you of the outcome.
To inform the relevant manager or department of your application.
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Details of your qualifications, experience, employment history (including job titles, salary and working hours)
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From you, in the completed application form and interview notes (if relevant)
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Legitimate interest: to carry out a fair recruitment process.
Legitimate interest: to make an informed decision to shortlist for interview and (if relevant) to recruit.
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To make an informed recruitment decision.
The person making the shortlisting decision will receive pseudonymised or anonymised details only; if you are invited for interview, the interviewer will receive non-anonymised details.
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[Your name, contact details and details of your qualifications, experience, employment history and interests]
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[From you, in the completed application form and interview notes (if relevant)]
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[Legitimate interest: to carry out a fair recruitment process]
[Legitimate interest: if you are unsuccessful in your application, your details may be passed on to an associated employer to see if they have any suitable vacancies]
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[To see whether an associated service area has any similar vacancies, but only with candidate authorisation]
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Your special category data: racial or ethnic origin, sex and sexual orientation, religious or similar beliefs
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From you, in a completed anonymised equal opportunities monitoring form.
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To comply with our legal obligations and for reasons of substantial public interest (equality of opportunity or treatment).
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To comply with our equal opportunities monitoring obligations and to follow our equality and other policies
For further information, see * below
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Information regarding your criminal record (criminal offence data)
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From you, in your completed application form
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To comply with our legal obligations.
For reasons of substantial public interest (preventing or detecting unlawful acts, suspicion of terrorist financing or money laundering in the regulated sector and protecting the public against dishonesty).
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To make an informed recruitment decision.
To carry out statutory checks.
Information shared with DBS and other regulatory authorities as required.
For further information, see * below
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Details of your referees
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From your completed application form
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Legitimate interest: to carry out a fair recruitment process.
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To carry out a fair recruitment process.
To comply with legal/regulatory obligations.
Information shared with relevant managers, HR personnel and the referee.
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Part 2 - Before making a final decision to recruit
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The information the Council collects
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How the Council collects the information
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Why the Council collects the information
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How the Council uses and may share the information
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Information about your previous academic and/or employment history, including details of any conduct, grievance/ or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers ☐
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From your referees (details of whom you will have provided).
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Legitimate interest: to make an informed decision to recruit.
To comply with our legal obligations.
Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice.
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To obtain the relevant reference about you.
To comply with legal/regulatory obligations.
Information shared with relevant managers and HR personnel.
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Information regarding your academic and professional qualifications ☐
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From you, from your education provider, from the relevant professional body.
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Legitimate interest: to verify the qualifications information provided by you.
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To make an informed recruitment decision.
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Information regarding your criminal record, in criminal records certificates (CRCs) and enhanced criminal records certificates (ECRCs) ☐
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From you and from the Disclosure and Barring Service (DBS).
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To perform the employment contract.
To comply with our legal obligations.
Legitimate interest: to verify the criminal records information provided by you.
For reasons of substantial public interest (preventing or detecting unlawful acts, suspicion of terrorist financing or money laundering in the regulated sector and protecting the public against dishonesty).
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To make an informed recruitment decision.
To carry out statutory checks.
Information shared with DBS and other regulatory authorities as required.
For further information, see * below.
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Information regarding any fraudulent activity you may have been involved in
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From you and from CIFA
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For reasons of substantial public interest (preventing or detecting fraud, other unlawful or dishonest conduct, malpractice, and other seriously improper conduct protecting the public against dishonesty).
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To make an informed recruitment decision.
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Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information ☐
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From you and, where necessary, the Home Office.
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To enter into/perform the employment contract.
To comply with our legal obligations.
Legitimate interest: to maintain employment records.
To carry out obligations and exercise rights in employment law.
For reasons of substantial public interest (preventing or detecting unlawful acts).
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To carry out right to work checks.
Information may be shared with the Home Office.
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A copy of your driving licence ☐
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From you
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To enter into/perform the employment contract.
To comply with our legal obligations.
To comply with the terms of our insurance.
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To make an informed recruitment decision.
To ensure that you have a clean driving licence.
Information may be shared with our insurer.
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You are required (by law or in order to enter into your contract of employment) to provide the categories of information marked ‘☐’ above to us to enable us to verify your right to work and suitability for the position.
* Further details on how we handle sensitive personal information and information relating to criminal convictions and offences are set out in our data protection policy and policy on criminal records information. These policies are available from the HR department.
