The FDF will ensure that data is always processed in accordance with the provisions of relevant data protection legislation, including the General Data Protection Regulation (GDPR).
What information does the FDF Collect?
FDF will collect personal information about job applicants through our application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider.
From time to time, FDF may collect additional personal information from an applicant. If FDF requires to obtain additional personal information this policy will be updated or applicants will be notified.
How and why do FDF use your information?
This policy, together with the information contained in the table of applicant data, constitutes the information that FDF will hold about job applicants, the purpose for which this data is held and the lawful basis on which it is held. The FDF may process personal information without job applicants' knowledge or consent, in compliance with this policy, where this is required or permitted by law.
If the purpose for processing any piece of data about job applicants should change, we will update the table of applicant data.
Fair processing principles
In processing job applicants' data, the following principles will be adhered to. Personal data will be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that are clearly explained and not used in any way that is incompatible with those purposes;
- Relevant to specific purposes and limited only to those purposes;
- Accurate and kept up to date;
- Kept only as long as necessary for the specified purposes; and
- Kept securely.
Lawful processing of personal data
Personal information will only be processed when there is a lawful basis for doing so. Most commonly, FDF will use personal information in the following circumstances:
- when it is needed to perform job applicants' contracts of employment;
- when it is needed to comply with a legal obligation; or
- when it is necessary for the Company's legitimate interests (or those of a third party) and job applicants' interests and fundamental rights do not override those interests.
FDF may also use information in the following rare situations:
- when it is necessary to protect applicants' interests (or someone else's interests); or
- when it is necessary in the public interest [or for official purposes].
Lawful processing of sensitive personal data and information about criminal convictions
FDF may process special categories of personal information in the following circumstances:
- In limited circumstances, with explicit written consent;
- in order to meet legal obligations;
- when it is needed in the public interest, such as for equal opportunities monitoring; or
- when it is needed to assess working capacity on health grounds, subject to appropriate confidentiality safeguards.
FDF does not envisage that it will hold information about criminal convictions. If it becomes necessary to do so, FDF will only use this information where it has a legal basis for processing the information. This will usually be where such processing is necessary to carry out the Company's obligations.
Less commonly, FDF may process this type of information where it is needed in relation to legal claims or where it is needed to protect a job applicant's interests (or someone else's interests) and the applicant is not capable of giving consent, or where an applicant has already made the information public.
Consent to data processing
FDF does not require consent from job applicants to process most types of applicant data. In addition, the FDF will not usually need consent to use special categories of personal information in order to carry out legal obligations or exercise specific rights in the field of employment law.
In limited circumstances, applicants may be asked for written consent to process sensitive data. In those circumstances, applicants will be provided with full details of the information that is sought and the reason it is needed.
Where job applicants have provided consent to the collection, processing and transfer of personal information for a specific purpose, they have the right to withdraw consent for that specific processing at any time. A request will need to be made to Recruitment@fdf.org.uk or the HR team. Once the FDF has received notification of withdrawal of consent it will no longer process information for the purpose or purposes originally agreed to, unless it has another legitimate basis for doing so in law.
Automated decision making
FDF does not envisage that any decisions will be taken about applicants using automated means, however applicants will be notified if this position changes.
How long will we keep your information?
The FDF will conduct regular reviews of the information held and will only retain job applicants' information for as long as necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of personal information are set out in the table of applicant.
In some circumstances FDF may anonymise personal information so that it can no longer be associated with individual job applicants, in which case the FDF may use such information without further notice to applicants. After the stated data retention period has expired, the FDF will securely destroy applicants' personal information
How do we protect and store your information?
Once we receive your information, FDF has put in place appropriate security measures and procedures to prevent accidental loss, unauthorised access or use, to keep your information safe.
FDF has put in place procedures to deal with any data security breach and will notify applicants and any applicable regulator of a suspected breach where legally required to do so.
How do we share your information with others?
FDF may share personal information with trusted third parties. The FDF requires third parties to respect the security of applicant data and to treat it in accordance with the law. The FDF may also need to share personal information with a regulator or to otherwise comply with the law.
FDF may also share applicant data with trusted third-party service providers where it is necessary to administer the working relationship with applicants or where FDF has a legitimate interest in doing so. The following third-party service providers process personal information about applicants for the following purposes:
- Recruitment Agencies – sourcing and sharing of candidate personal/ sensitive data in accordance with the law
- Various specialist online job boards – sharing of candidate personal/ sensitive data in accordance with the law
- Reference contact details – sharing of candidate personal/ sensitive data in accordance with the law
Transfer of data outside the EU
The information that FDF collects from the job applicant is stored on information technology systems located in the European Economic Area (EEA) which are operated by our third-party service providers under our instruction and control. If our service providers transfer any information, it will be done with relevant protection in place and only with our agreement.
Job Applicant rights
Job Applicants are under a duty to inform FDF of any changes to their current circumstances. Where an Applicant has concerns regarding the accuracy of personal information held by FDF, the Applicant should contact the Head of HR at FDF to request an amendment to the data.
Under certain circumstances, job applicants have the right to:
- Request access to personal information (commonly known as a “data subject access request”).
- Request erasure of personal information.
- Request the restriction of processing of personal information.
If an applicant wishes to make a request on any of the above grounds, they should contact the Head of HR in writing. Please note that, depending on the nature of the request, FDF may have good grounds for refusing to comply. If that is the case, the applicant will be given an explanation by FDF.
Applicants will not normally have to pay a fee to access personal information (or to exercise any of the other rights). However, FDF may charge a reasonable fee if the request for access is clearly unfounded or excessive. Alternatively, FDF may refuse to comply with the request in such circumstances.
The FDF may need to request specific information from the applicant to help confirm their identity and ensure the right to access the information (or to exercise any of the 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.
Contact the FDF
The Company's responsibility for compliance
If job applicants have any questions about this policy or how the FDF handles personal information, they should contact the Head of Corporate Services – Digital, IT and Management Services at the address below.
The Food and Drink Federation
10 Bloomsbury Way
London, WC1A 2SL
Contacting the regulator
Applicants 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 www.ico.org.uk/concerns