RECRUITMENT PRIVACY POLICY

INTRODUCTION

Steer Automotive Group takes the protection of your personal information seriously and is committed to protecting the privacy of the personal information that you share with us or is collected by us during our interactions with you. We need to collect, use and store certain personal information about individuals who apply for roles with us (whether as an employee, worker or contractor) in connection with our recruitment process. 

Steer Automotive Group Limited (company number 08239702 with its registered office address at 13 March Place, Gatehouse Way, Aylesbury, Buckinghamshire, HP19 8UG) is a “data controller” of the personal data that candidates provide to us. Any reference in this privacy policy to Steer Automotive Group, Steer, ‘we’ or ‘us’ means Steer Automotive Group Limited and all other companies within the Steer group of companies.

Please read this privacy policy carefully as it describes how we collect, use, store and share your personal information. It also sets out the rights you have in relation to such data.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

WHAT PERSONAL INFORMATION DO WE COLLECT:

We collect, use, store and share a range of personal information about you. This includes:

• Name
• Title
• Preferred name (e.g. known as)
• Address
• Email address
• Telephone numbers
• Date of birth / age
• Gender
• Nationality
• Qualifications, skills and experience
• Professional memberships
• Employment history
• Information included in your CV and covering letter
• Information provided during an interview
• Information about criminal convictions and offences 
• References
• Information about your current level of remuneration, including benefit entitlements
• Information about your right to work in the UK 
• Information about your health and any disabilities
• CCTV images (upon attendance for interview at our premises)
• Information regarding protected characteristics for the purpose of equal opportunities monitoring, including race, sexual orientation and religious beliefs

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We use different methods to collect personal information about candidates, including from:

• You, the candidate. For example, data contained in your CV, application form, or obtained from your passport or other identity documents or collected through interviews or other forms of assessment.
• Recruitment agencies. For example, candidate CVs.
• References supplied by former employers.
• References supplied by your named referees.

WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?

We will use your personal information to:

• Assess your skills, qualifications, experience and suitability for the role.
• Carry out background and reference checks, where applicable.
• Communicate with you about the recruitment process.
• Keep records relating to our hiring processes.
• Comply with legal requirements. For example, it is a requirement to check a successful applicant’s eligibility to work in the UK before employment starts. 

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 vacancy. We also need to process your personal information to decide whether to enter into a contract of employment (or a consultancy agreement) with you.

Steer has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from candidates allows Steer to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. Steer may also need to process data from job applicants to respond to and defend against legal claims. 

We will use your sensitive personal information in the following ways:

• We will use information about your health and disability status to consider whether we need to make reasonable adjustments during the recruitment process. For example, whether adjustments need to be made for you to attend an interview or assessment centre.
• We will collect information about your criminal convictions history (such as details of any unspent convictions) in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role as certain roles require a high degree of trust and integrity since they are customer facing and involve attending a customer’s home to collect or deliver a vehicle. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.
• We will use information about your nationality, ethnic origin, gender, sexual orientation, health, age, and religion or belief, for the purposes of equal opportunities monitoring and reporting. Any data that we use for these purposes is anonymised and is collected with the express consent of candidates, which can be withdrawn at any time.
• Where it is needed in relation to disputes and legal claims.

AUTOMATED DECISION MAKING

We do not currently use any automated decision making as part of our recruitment process, although we may use filtering questions in order to assist us with the administration and progression of your application throughout some stages of the application process. 

DATA SHARING - WHO HAS ACCESS TO YOUR PERSONAL INFORMATION

Your information will be shared internally, including with members of the Recruitment and People teams, the manager recruiting the role, interviewers and other recruitment decision-makers, if access to the data is necessary for the purposes of assessing and processing your application, and for onboarding and background checks if your application is successful.

We will only share your information with third parties if your application is successful and we make you an offer of employment. We may share your data with former employers to obtain references for you and academic institutions to validate information you have provided.

We use a third-party applicant tracking system (ATS) which securely stores your personal information for us once you have made an application in order to enable the relevant hiring managers and recruiters to consider your application.

All our third-party service providers are required to take appropriate security measures to protect your personal information. They are only permitted to process your personal data for specified purposes and in accordance with our instructions.

We do not envisage transferring the personal information we collect about you outside the UK.

DATA SECURITY

We take the security of your personal information seriously. 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 those team members and 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.

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 DO WE KEEP YOUR PERSONAL INFORMATION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting or reporting requirements. 

To determine the appropriate retention period for personal data we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If your application is unsuccessful, we will retain your personal information for a period of 6 months after we have communicated our decision to you. 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.

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.

If your application is successful, personal information gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be set out and available to you in our People Privacy Policy and Data Retention Policy. 

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. 

WHAT IF YOU DO NOT PROVIDE PERSONAL INFORMATION THAT WE REQUEST

If you fail to provide information during the recruitment process, 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 properly or at all. For example, if we require references for the role and you fail to provide us with relevant details, we will not be able to take your application further.

YOUR RIGHTS

You have a number of rights under data protection laws (some of which are highlighted below). If you would like to exercise any of your rights, please email us on recruitment@steer.co.uk or write to us at Steer Automotive Group, 13 March Place, Gatehouse Way, Aylesbury, Buckinghamshire, HP19 8UG F.A.O Group Talent Development Manager.

If you exercise any of your rights, we may ask for proof of identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also ask you for further information in relation to your request to help identify your personal information and speed up our response. 

You will not have to pay a fee to exercise your rights, although we reserve the right to charge a reasonable fee if your request for access is unfounded or excessive. We may refuse to comply with the request in these circumstances. 

Your rights include:

• Right of access/obtaining copies of your information
  You have the right to ask us for details of the personal information we hold about you. 

• Amending your information
  It is important that the personal information we hold about you is accurate and current. If your details change, or if you think any information we have about you is wrong or incomplete, please contact us using the details given above. 

• Right to object
  You have the right to object to the processing of your personal information where we are relying on a legitimate interest as the legal ground for processing. Should you wish to object, please set out the specific reasons why you are objecting. These reasons should be based upon your particular situation.
  
  
• Right to be forgotten
  You have the right to have your personal information erased in certain circumstances. More information about your rights is available on the ICO website at www.ico.org.uk.

FURTHER INFORMATION

If you have any questions about this privacy policy or how we treat your personal information, please email us on recruitment@steer.co.uk or write to us at Steer Automotive Group, 13 March Place, Gatehouse Way, Aylesbury, Buckinghamshire, HP19 8UG.

If you are not satisfied with how we respond to any request or query you raise, then you can complain to the Information Commissioner’s Office. Information about how to do this is available on the ICO website at www.ico.org.uk.

This privacy policy does not form part of any contract of employment you might enter into with Steer Automotive Group and does not create contractual rights or obligations. It may be amended by us at any time. Nothing in this privacy policy is intended to create an employment relationship between you and Steer Automotive Group.

Last updated: 3 December 2024