Last updated: October 2018
This Privacy Notice (“Notice”) is intended to provide information regarding how any personal information is collected from you during the permanent / contractor / temporary worker application process. It relates to personal data or special category personal data (defined under data protection law) about you that we refer to as personal information in this document.
Omni Resource Management Solutions Limited (Omni RMS) is the dedicated recruitment partner of The Drax Group (including Drax Power Limited, Haven Power Limited and Opus Energy Limited). Omni RMS’s registered office is at Charter House, Woodlands Road, Altrincham, Cheshire, WA14 1HF and are a company registered in England and Wales under company number 013278470. Omni RMS are registered on the Information Commissioner’s Office Register of Data Controllers under registration number Z7378991 and act as a data controller and a data processor. Omni RMS’s designated Data Protection Lead can be contacted at firstname.lastname@example.org.
WHO COLLECTS THE INFORMATION
The relevant company in the Drax Group (“Company”, “we”, “us”, or “our”) is the data controller of personal information provided by you or collected about you during the application process. Omni RMS will also act as a data controller in relation to their part of the application process and may as part of it be our processor. The Drax Group and Omni RMS take great care to ensure that the information it collects is processed in a way that meets legal and statutory obligations. It is important that you read this Notice so that you are aware of how and why we are using your personal information and how we will treat it. Note, at times “we” will also mean Omni RMS.
The Drax Group and Omni RMS respect your privacy and are committed to protecting your personal information. Our Data Protection Managers/ Data Protection Lead are responsible for overseeing questions in relation to this Notice. If you do have any questions about this Notice, you can contact us using the details set out at the end of this Notice in the “Contacting Us” section.
Your personal information may also be shared across the companies within the Drax Group, including Drax Power Limited, Haven Power Limited and Opus Energy Limited and so, in this Notice, references to ‘we’ or ‘us’ mean the Company and our group companies
LEGAL BASIS AND PURPOSE FOR PROCESSING
The Drax Group and Omni RMS will collect various types of personal information from you during the application process. Further details of how we use your personal information are set out below.
In the section below, we have indicated with asterisks whether we need to process your personal information:
* to enter into and/or to perform an employment contract with you;
** to pursue our legitimate interests of processing your application, provided that your interests and fundamental rights do not override those interests;
*** to enable us to comply with our legal obligations (e.g. our obligation to check that you are eligible to work in the United Kingdom); and/or
**** with your consent.
The Drax Group and Omni RMS will use your personal information for the purposes of processing your permanent / contractor / temporary worker application. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
WHAT INFORMATION DO WE COLLECT?
To decide whether to shortlist you as an applicant and to contact you in relation to your application**, The Drax Group and Omni RMS may need to collect the following information about you up to and including the shortlisting stage of the recruitment process:
Your name and contact details (e.g. address, home and mobile phone numbers, email address);
Your curriculum vitae/resume;
Details of your qualifications, experience, employment history (including job titles and salary); and
Your eligibility to work in the United Kingdom.
The Drax Group and Omni RMS will not be able to process your application without this information.
If we decide to invite you to attend an interview and/or after we have made a conditional job offer, we may need to collect the following personal information about you to allow us to make the necessary interview arrangements and/or make our final decision as to whether to recruit you**:
Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information to enable us to verify your right to work in the United Kingdom***;
Copies of documents containing your name, address and date of birth to enable us to verify your identity**;
A copy of your driving licence, if relevant for your role, to enable us to check you may legally drive*;
Information about your previous academic and/or employment history from references obtained about you from previous employers and/or education providers**;
Information regarding your academic and (where relevant) professional qualifications**;
Information regarding your unspent criminal convictions obtained through a relevant Disclosure and Barring Service (DBS) check**.
The Drax Group and Omni RMS are under a statutory obligation to collect information from you regarding your nationality and immigration status and information from related documents, and a copy of your driving licence for the purposes explained above.
We will not carry out any solely automated decision making using your personal information during the application process.
SPECIAL CATEGORIES OF PERSONAL DATA - SENSITIVE PERSONAL INFORMATION – AND INFORMATION ABOUT CRIMINAL CONVICTIONS
The Drax Group and Omni RMS may use your particularly sensitive personal information (known as special categories of personal data) in the following ways:
We may use information about your race or national or ethnic origin, religious beliefs, or sexual orientation to ensure meaningful equal opportunity monitoring and reporting; and
We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process or if you are subsequently offered employment with us.
Where we use such special categories of personal data, we are processing on the basis of it being necessary for the purposes of carrying out our obligations and exercising specific rights as an employer.
The Drax Group and Omni RMS will use information about your unspent your criminal convictions to assess whether your employment could pose an unacceptable risk to the company, its customers or its
Employees/workers. We will only use information relating to criminal convictions where the law allows us to do so.
DISCLOSURE OF YOUR INFORMATION
The Drax Group and Omni RMS may have to share your personal information collected during the application process with our group companies relevant to the recruitment process (based in the United Kingdom) and who provide HR, Security, IT or administration services or undertake management reporting. Furthermore, we may share your personal information with selected third-party service providers that provide online psychometric or verbal and numerical testing (such as IKM).
The Drax Group and Omni RMS will also disclose your personal information to third parties:
if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements; or to protect the rights, property, or safety of us, our applicants, employees, customers and providers.
We require all service providers, including, Omni RMS and group companies, to respect the privacy and security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
WHERE INFORMATION MAY BE HELD
In some cases, a service provider or their sub-processor may be based elsewhere in the European Union (EU) and so, they are required to comply with European data protection law. On occasion, we may appoint a third-party service provider whose operation or a server or sub-processor may be based outside of the EU. As part of our Vendor Management Policy, we carry out due diligence on our third-party providers and assess whether your personal information will be transferred to them or accessed by them from outside the EU. If that is the case, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
where we use providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EU and the US. You can view certifications at www.privacyshield.gov; or
where we use certain service providers who are not in a ‘adequate’ country or part of the Privacy Shield, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU, called an EU Model Clause Agreement.
If you would like to know the specific mechanism used by us when transferring your personal information out of the EU, please contact us using the details in the “Contacting Us” section at the end of this Notice.
STORAGE OF YOUR PERSONAL INFORMATION
As a Drax Group permanent / contractor / temporary
The Drax Group and Omni RMS will only retain the personal information that we obtain from you or about you for as long as necessary to fulfil the purposes we collected it for, namely our recruitment process but also, for the purposes of satisfying any legal or reporting purposes.
Personal information relating to unsuccessful applicants will be deleted 12 months following completion of our recruitment process. If, however, you make contact with us or further applications, this will trigger the 12 months retention period again. In any case, when deleting your personal information, we will retain certain anonymised data for management information purposes as below
Omni RMS may rely on your consent to retain your personal information in order to contact you in relation to any vacancies that may be of interest to you. You have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact email@example.com. Once we have received notification that you have withdrawn your consent to be informed of vacancies, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
The Drax Group and Omni RMS take the security and confidentiality of your personal information very seriously. We will use strict procedures and security features aimed at preventing your personal information from being accidentally lost, used or accessed in an unauthorised way, such as corporate firewalls protecting multi-layer server configuration and penetration testing. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data protection laws provide you with the following rights, to:
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 in certain circumstances. 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);
request the restriction of processing of your personal information, for example if you want to establish its accuracy or the reason for processing it; and
request the transfer of your personal information to another party.
You also have the right to object to the 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.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
The Drax Group and Omni RMS may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your 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.
The Drax Group and Omni RMS do our best to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You 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. The ICO can be contacted by telephone on 0303 123 1113 or by post as follows: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF or via email at firstname.lastname@example.org. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance using any of the details set out below in the “Contacting Us” section.
If you have any queries, comments or requests regarding this Notice or you would like to exercise any of your rights set out above, you can contact us as follows:
Omni (RMS) Limited
by email at email@example.com; or
by telephone at 0161 929 4343 and asked to be directed to the Data Protection Lead; or
by post at Omni (RMS) Limited, Charter House, Woodland Road, Altrincham, WA14 1HF addressed to the Data Protection Lead
The Drax Group
Drax Power Limited
by email at firstname.lastname@example.org; or
by telephone at 01757 612 372; or
by post at, Group Data Protection Officer, Drax Power Limited, Drax Power Station, Selby, North Yorkshire, YO8 8PH; or
via our Group Data Protection Officer at email@example.com
Haven Power Limited
by email at HR@havenpower.com; or
by telephone at 01473 277556 and asked to be directed to Recruitment; or
by post at The Drax Group, 32 The Havens, Ransomes Europark, Ipswich, IP3 9SJ addressed either to our Resourcing Manager or Data Protection Manager; or
Opus Energy Limited
by post at Resourcing Manager, Opus Energy, Opus Energy House, 6-10 The Lakes, Northampton NN4 7YD; or
via our Data Protection Manager at firstname.lastname@example.org
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