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Recruitment Privacy Policy V1

Focus (“We”, “Us”) are committed to protecting and respecting your privacy. This Privacy Notice (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to Us, will be processed by Us in connection with Our recruitment processes. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it.

Where you apply for a job opening posted by Us, these Privacy Notice provisions will apply to Our processing of your personal information in addition to Our other Privacy Notice which has been provided to you separately or is available on Our Website.

For the Purpose of the General Data Protection Regulation (“GDPR”) if you have any questions in relation to recruitment data:

Our Data Privacy Manager and data protection representatives can be contacted directly here:

How do We collect your personal data?

  • We collect the data directly from you.
  • There are numerous ways you can share your information with Us, and these may include:
  • Entering your details on the Focus Careers page as part of the registration process
  • Emailing your CV and information directly to Focus
  • Posting and hard copy of your CV and information to Focus
  • Via social media channels such as Facebook and LinkedIn
  • Information provided by you to Us at interviews / or by any other method
  • Obtained from your passport or other identity documents
  • Collected through interviews or other forms of assessment
  • We may also collect personal data about you from third parties, such as references supplied by former employers. We will seek information from third parties only once a job offer to you has been made and will request the contact details from you in order to do so.

The personal data provided by you and collected by Focus for the purpose of recruitment:

  • your name, address and contact details including email address and telephone number
  • CV, job application and any attachments that you upload to support your application
  • Details of your qualifications, skills, experience and employment history
  • Information about your current level of remuneration, including benefit entitlements
  • Whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process
  • Interview assessment, and notes taken during the interview process
  • References you share with Us
  • Messages between Focus and you
  • Information about your entitlement to work in the UK

What information is required and what if I don’t provide this information?

You will need to give the information marked as “required” in the application process. This information is so that We can process your application successfully. If you do not give the required information, We cannot unfortunately accept your application.

Who processes your data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles. We will not share your data with third parties, unless your application for employment is successful and We make you an offer of employment. We will then share your data with former employers to obtain references for you, and employment background check providers to obtain necessary background checks.

We use the following service providers for processing recruitment data:

Service Provider  Purpose Read More
Microsoft Office 365 Email accounts, calendar  Management

How do We use your personal data?

Lawful basis for processing

We rely on legitimate interest as the lawful basis on which We collect and use your personal data. Our legitimate interests are the recruitment of staff for Our business.

We use your data:

  • To consider your application in respect of a role for which you have applied
  • Consideration for future roles
  • To communicate with you in respect to the recruitment process
  • To find appropriate candidates to fill Our job openings
  • For the legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom We offer a job. We may also need to process data from job applicants to respond to and defend against legal claims
  • To process data to take steps, at your request, prior to entering into a contract with you. We may also need to process your data to enter into a contract with you
  • To check a successful applicant’s eligibility to work in the UK before employment starts. We would be required to take copies and hold a copy of your identity documents on your personal file
  • To process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. We process such information to carry out its obligations and exercise specific rights in relation to employment
  • For unsuccessful applications where We may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before We keep your data for this purpose and you are free to withdraw your consent at any time.

What are your rights?

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • access your personal data and certain other supplementary information that this Privacy Notice is already designed to address
  • require Us to correct any mistakes in your information which We hold
  • require the erasure of personal data concerning you in certain situations
  • receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object in certain other situations to Our continued processing of your personal data
  • otherwise restrict Our processing of your personal data in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • contact Us using Our Contact details below
  • let Us have enough information to identify you,
  • let Us have proof of your identity and address, and
  • let Us know the information to which your request relates.

These requests can all be made by sending an email to [email protected]

We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which We are lawfully entitled). Please note that We may keep a record of your communications to help Us resolve any issues which you raise.

Who do We share your data with?

Where appropriate and in accordance with local laws and requirements, We may share your personal data, in various ways and for various reasons, with the following:

  • Third party service providers who perform functions on Our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on Our business technology systems)
  • Third party outsourced IT and document storage providers where We have an appropriate processing agreement (or similar protections) in place.

How do We safeguard your personal data?

We are committed to taking all reasonable and appropriate steps to protect the personal information that We hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach. We limit access to your personal data 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.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

If you suspect any misuse or loss of or unauthorised access to your personal information please let Us know immediately.

Where We store your personal data

We store your personal data in Our own systems on secure servers. By submitting your personal data, you agree to Our method of storing your data.

How long do We keep your personal data?

If your application for employment is unsuccessful, the organisation will hold your data on file for twenty-four months after the end of the relevant recruitment process. If you agree to allow Us to keep your personal data on file, We will hold your data on file for a further twelve months for consideration for future employment opportunities. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed. You will be asked when you submit your CV whether you give Us consent to hold your details for the full twenty-four months in order to be considered for other positions or not. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper based) and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

Cookies and external websites

To provide a better service to you on Our website, We use cookies to collect data when you browse. See Our cookie policy on Our website here.

Changes to Our recruitment privacy policy

We reserve the right to change Our policy at any time.

What to do if you would like to file a complaint

We hope that We can resolve any query or concern you raise about Our use of your information. If you disagree with Our decision in relation to your request or you think your rights have not been respect, please contact Us.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area): state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at or telephone: 0303 123 1113.