Kaplan International Privacy Notice for Candidates
Last Revised: 25th May 2018
What is the purpose of this document?
Kaplan International is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. You should read this privacy notice given you are applying for work with us (whether as an employee or a worker). 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. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR). The Kaplan International company which acts as a data controller of your personal data depends on which role you have applied for. Please see the end of this notice for details of the relevant Kaplan International companies.
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we may hold about you
In connection with your application for work with us, we may 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 our application form, including name, title, address, telephone number, personal email address, employment history and qualifications.
- Any information you provide to us during an interview.
- Test results from any skills test we ask you to undertake or any written work we have asked you to complete as part of the selection process.
- Information, including your photo, which might be available on a publicly accessible source.
We may also collect, store and use the following "special categories" of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about candidates from the following sources:
- You, the candidate.
- Recruitment agencies.
- Background check providers.
- Credit reference agencies.
- Disclosure and Barring Service in respect of criminal convictions.
- Your named referees.
- Publicly accessible sources.
How we will use information about you
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
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 a suitable candidate to that role.
We also need to process your personal information to decide whether to enter into a contract with you.
Once you have submitted your application to us and where applicable completed any additional selection tasks such as online tests, pre-interview tasks or phone interviews, we will process that information to decide whether we wish to progress your application to the next stage, which is most likely to be a job interview with one or more members of the company. We will use the combined information gathered from the different stages of the process to decide whether to offer you employment. If we offer you employment, we will take up references and carry out a criminal record check as well as any other checks which we consider necessary to ensure your suitability for the role, before confirming your employment.
If you fail to provide personal information
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 may not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use particularly sensitive personal information
We may use your particularly sensitive personal information in the following ways:
- We may use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
- We may use information about your race or national or ethnic origin, or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
We envisage that we will process information about criminal convictions where necessary and appropriate for the role in question in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.
If we are legally required to carry out criminal record checks for the role in question or the role requires a high degree of trust and integrity, we will contact you about collecting the necessary information in order to carry out a criminal records check.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information with third parties (such as search and recruitment agencies, health screening providers and the Disclosure and Barring Service) and other entities in our group for the purposes of processing your application. 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.
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. Details of these measures may be obtained from our Data Protection Officer (see contact details below).
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.
How long will you use my information for?
We will retain your personal information for a period of up to 12 months after we have communicated to you our decision about whether to appoint you to a role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy and applicable laws and regulations.
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.
Rights of access, correction, erasure, and restriction
Your rights in connection with personal information
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.
If you want 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 Data Protection Officer in writing.
Data protection officer
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO.
Name of DPO: Rachael Convery
Email address: firstname.lastname@example.org
Postal address: 2nd Floor, Warwick Building, Kensington Village, Avonmore Road, London W14 8HQ.
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.
Kaplan International companies which act as a data controller of your personal data
Unless stated otherwise, all companies are registered at 2nd Floor, Warwick Building, Kensington Village, Avonmore Road, London W14 8HQ.
Kaplan International English:
- UK HQ: Aspect Education Limited (company number 04053877).
- UK Language Schools: Aspect International Language Academies Limited (company number 02162156).
- Ireland: Aspect International Language Schools Limited (company number 274271 with registered address at 3rd Floor Kilmore House, Park Lane, Spencer Dock, Dublin 1, Ireland).
- France: Aspect S.A.R.L. (RCS 350 061 222 RCS PARIS with registered address at 14 Boulevard Montmartre, 75009, Paris, France).
Kaplan International Pathways:
- UK HQ: Kaplan International Colleges U.K. Limited (company number 05268303).
- Bournemouth University International College: Kaplan Bournemouth Limited (company number 08291927).
- Glasgow International College: Kaplan Glasgow Limited (company number 05976922).
- Kaplan International College London: Kaplan International College London Limited (company number 06533974).
- Liverpool International College: Kaplan Liverpool Limited (company number 06217892).
- Nottingham Trent International College: Kaplan NT Limited (company number 05268287).
- The University of Nottingham International College: Kaplan Nottingham Limited (company number 10199220).
- University of Brighton International College: Kaplan Brighton Limited (company number 07331979).
- University of Essex International College: Kaplan Essex Limited (company 10846169).
- University of West England, Bristol’s International College: Kaplan UWE Limited (company number 08102562).
- University of York International Pathway College LLP: (company number OC400882 with registered address at Heslington Hall, Heslington, York, YO10 5DD).
- University of Essex Online: Kaplan Open Learning (Essex) Limited (company number 06245017).
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact Human Resources or the Data Protection Officer.