Active Human Capital Ltd takes seriously its responsibility to protect and manage personal data collated during the course
of its business practice.
Consequently, a Data Protection Policy is in place which intends to provide clear management direction on
responsibilities and procedures in order to safeguard this personal data. This includes both physical and bureaucratic
security measures.
All members of staff are made aware of these procedures and requested to adhere to them and will receive relevant
training where necessary.
Should there be any breach of these procedures an investigation will be instigated.
In the event of personal data being destroyed or lost an established business continuity plan is in place.
Policy Objectives
1) To promote trust and confidence within the workplace
2) To encourage good housekeeping
3) To Protect the Company should any cases of legal action arise
4) To encourage staff to respect the personal data of clients and candidates
5) To aid organisations in meeting other legal requirements e.g. Human Rights Act
6) To Remain consistent with European legislation
7) To help prevent the misuse of personal, sensitive and confidential information
The Data Protection Act
The eight enforceable principles of good practice with which anyone processing personal information must comply
stipulate that data must be:
1) Fairly and lawfully processed
2) Processed for limited purposes
3) Adequate, relevant and not excessive
4) Accurate and up to date
5) Not kept longer than necessary
6) Processed in accordance with the individual’s rights
7) Secure
8) Not transferred to countries outside the European Economic area unless the country has adequate protection for the individual
The Management of Company Data
- An appointed member of staff will ensure that all procedures continuously comply with the Act
- We will ensure that all individuals are aware of their responsibilities with regard to the Act and adhere to it
- There will be awareness of the personal data which exists and who is responsible for it
- We will avoid excessive collection of personal data and that which is irrelevant and ensure the justification of any sensitive data in accordance with the Act
- Staff will be informed that there are serious consequences should they disclose personal data inappropriately
- A notification will be made with the Information Commissioner of the Data Controller and of his or her processing of personal data on behalf of the Company
- Employees will be involved in the decision-making process with regard to the processing of personal data
The Use of Personal Data within Company Advertising
- Advertising will clearly state the name of the Company to whom applicants are forwarding their information and how it is to be used where applicable
- Candidates will be informed as soon as possible of the Client to whose vacancy they are applying and to whom their personal details are being forwarded
The Collection of Personal Data on Application Forms
- Application forms will state to whom the information is being provided and how it will be used
- Only personal data which is relevant to the recruitment decision will be sought
- Information regarding criminal convictions will only be requested if relevant to the role
- Applicants will be made aware that information they provide may be verified
- If sensitive data is collected then we will ensure that a sensitive data condition is satisfied (i.e. consent of the individual)
- A secure method will be provided for forwarding applications
The Verification of Personal Data which is Supplied
- Candidates will be made aware of the verification process for information supplied
- Written consent from the candidate will be obtained if information about them is to be requested from a third party
- Should any verifications prove detrimental the candidate will have the opportunity to explain any adverse feedback
The Use of Personal Data for Short-Listing Purposes
- Procedures for short listing candidates for assignments using personal data will remain consistent
- Where automated methods are used, candidates will be informed accordingly and serious consideration will be given to any feedback the candidate may have with regard to the results before a final decision is made
- If testing is to be employed i.e. psychometric tests then we will ensure that the person carrying out and interpreting these tests is trained to do so
Information Gathering for Interview Purposes
- Only information which is necessary and justified will be noted and retained during the interview
Pre-Employment Vetting Procedures
- This method will only to be employed if a risk element is involved and then will only to be used if no alternative is available
- This procedure will be introduced at an appropriate point during the recruitment process and then only with regard to successful candidates
- Candidates will be made aware that vetting will take place and of the method to be used
- This method will only be used to obtain specific information and not for intelligence gathering and its extent justified
- Only sources where it is likely that information will be released will be approached
- Unreliable sources will be identified and, with this in mind, serious consideration will be given to any adverse response from the candidate that the information from such a source may generate
- Candidates will be advised if information is to be collected from a third party
- Signed consent will be obtained from the candidate in order to obtain information or documentation from a third party
How Information Collected during the Recruitment Process will be Retained
- Recruitment records will only be retained for as long as is necessary
- Information will be destroyed within a given time frame
- Serious consideration will be given as to which information will be kept on file should the candidate be hired and any irrelevant information deleted
- Should criminal conviction information be attained then this will be deleted if and when it is verified by means of a Criminal Records
- Bureau disclosure or only retained if vital to a current issue
- Should unsuccessful candidates information be kept on file then they will be informed accordingly and given the opportunity to have this removed if they so wish
- Personal data obtained during the recruitment processed will be securely stored or destroyed
