Data privacy notice for job applicants

1. About Us

1.1 THÉSÉE S.A.S (referred to as “the Leyton Group”) is made up of different legal entities, details of which can be found at: https://leyton.com/uk/about-us. Leyton UK Limited forms part of the Leyton Group.  For the purposes of this Notice reference to “we” or “us” is intended to refer to Leyton UK Ltd which is the controller responsible for your personal data.

1.2 You are being given 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

1.3 This notice does not form part of any offer of employment.  It is reviewed regularly and we may amend it at any time to reflect any changes in the way in which we process your personal data. Any changes will be posted to this URL/page.  It is important that the information we hold about is you accurate and current and we would urge you to keep us informed of your personal data changes during your relationship with us.

2. The data we collect

2.1 “Personal data” is any information about a living individual from which they can be identified using that information along or in conjunction with other information.  This will typically include name, ID number, location data, any online identifier (such as IP address), or any factor specific to the physical, physiological, genetic, mental, economic or social identity of that person. It does not include data where any potential identifiers have been removed (anonymous data) or data held in an unstructured file.

2.2 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 your application form, including name, title, address, telephone number, personal email address, employment history, and qualifications.
  • Any information you provide to us during an interview.
  • Information provided in voicemails, emails, correspondence and other communications created, stored or transmitted by you in order to progress your application through the recruitment process.

This will typically take the form of contact information (including your name, address, telephone number(s), email address(es), URL’s to online profiles such as LinkedIn and other social media or online platforms).  It will also include details about your education, training activities and past employment history, as well as information regarding your future career aspirations / intentions, salary sought and availability for work information.

Where we have sought evidence of your right to work, we will also process identification data such as passport / drivers licence number(s) and detail, National Insurance number, and immigration status.

2.3 There are “special categories” of more sensitive personal data which are more private in nature and therefore require a higher level of protection, such as genetic data, biometric data, information about sex life or sexual orientation, race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and health. For the purposes of this notice, personal data relating to criminal convictions will also fall within the description of special category personal data.

2.4 On application, we may invite you to complete a diversity survey which will record:

  • Your ethnicity
  • Your gender and gender identity
  • Whether you identify as transexual
  • Your sexual orientation
  • Details regarding any disability
  • Your religious belief
  • Your age

We ask these questions to help us adhere to diversity requirements (such as Gender Pay Gap Reporting).

2.5 Where we have a legitimate reason to do so (usually because the role you are applying for or you are being considered for requires additional due diligence measures) we may process information about criminal convictions.  This will be processed as special category data (referred to above).


3. How we collect your data

3.1 Typically, we will have collected our data straight from you, the data subject.  We may also, to the extent that is permittable, collect further data from third parties including recruiters, past employers, referees, identification and other background checking services.  Further, we may collect data about you from publicly available sources including online profiles and websites.  Additionally, we may collect peripheral data as part of your online application process including your IP address, location, browser type etc.

3.2 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. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.


4. Lawful basis for processing

4.1 We will only process your personal data where we have a lawful basis to do so.  This will typically be for the performance of selection and recruitment into the employment of our business.  It is in our legitimate interests to decide whether to appoint you to a role since it would be beneficial to our business to appoint someone to that role.

5. How we will use your personal data

5.1 We will use your personal data to assess your skills, qualifications, and suitability for the work or role you have applied for or any other role that might be suitable for you in the event of a speculative application.  Having received your CV and covering letter, 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 role. If we decide to offer you the role, we will then take up references before confirming your appointment.

5.2 We may also use your personal data to undertake background and reference checks, to communicate with you regarding the recruitment process, and to otherwise comply with our legal and regulatory requirements.  Ultimately, your personal data will be used to determine whether to appoint you to a role within our business and this will inevitably include processing your data for the purpose of evaluating your suitability, arranging and conducting interviews of you and negotiating contractual terms with you.

5.3 “Automated decision-making” takes place when an electronic system uses information to make a decision without human intervention.   You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. However, we will notify you in writing if this position changes.

5.4 We may use anonymised data of applicants and candidates for analytical purposes and to ensure that we are complying with our legal, regulatory and corporate social responsibility obligations and requirements.


6. Security measures

6.1 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.

6.2 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.

6.3 Your personal data is stored in a variety of locations, including electronically on our secure servers and in hard-copy form in access-restricted, locked filing cabinets.


7. Sharing your personal data

7.1 We will only share your personal information with the following third parties for the purposes of processing your application: Leyton’s parent company, other entities in the group, IT system management.

7.2 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.


8. International Processing

8.1 Our data centres are controlled by the Leyton Group and are located in France.  They are managed by Moroccan based Leyton Group employees and certified ICO 270001, SOC 2 PART II. We have automatic alerts which prevent intrusions as well as malware protection, firewall and SSL inspection, anti-spyware, application control, antivirus.

8.2 Where we share your personal data for business administration reasons within the Leyton Group but outside of the UK and EEA, we do so pursuant to group level data sharing agreements.

8.3 We may also share your personal information with third parties who may be based outside of the UK / EEA in circumstances where it is otherwise lawful to share your data (these will typically be service providers such as Team Tailor, LUCCA, Cascade or other organisations to supply and support our recruitment operations).  Where we transfer personal data outside of the UK and EEA, we will only do so pursuant to a data sharing agreement which ensures personal data as adequately protected in the international territory as we would expect it to be protected in the UK and EEA.

9. Retention Period

9.1 We retain the personal data in accordance with a Retention Schedule which assesses the nature of the personal data, the purpose of its processing and the reasonableness of its retention.  Personal data will not be retained for longer than is necessary to fulfil the purpose for which it was collected and where personal data is required to be held in a dormant state to satisfy legal or regulatory obligations it will be minimised.

9.2 CV’s and covering letters are retained for 6 months and thereafter they are deleted from our system.  These may be retained longer in circumstances where an individual is recruited.  In any other circumstance, if we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately seeking your explicit consent to retain your personal information for a fixed period on that basis.  You may positively decline.  Failure to respond to such a request will result in your information being deleted upon expiry of 12 months of inactivity.

10. Your legal rights

10.1    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.

10.2 The right of access and/or right of erasure may not apply where we are processing your personal for the purposes of management forecasting or management planning in relation to a business or other activity.  Exemptions are subject to specific conditions detailed at Schedule 2 of the Data Protection Act 2018.  If you would like 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 our DPO or email dpm@leyton.com

10.3 If you wish to make a complaint about the manner in which you believe your data is being processed, we would encourage you to raise this with our DPO in the first instance.  Ultimately, complaints may be made to the Information Commissioner’s Office (ICO), the UK regulator for data protection (www.ico.org.uk / Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom).