As part of our recruitment process, we collect and process personal data relating to job applicants/candidates. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
Lifesure is a general insurance intermediary (a “broker”) who underwrites insurance policies as an agent of insurers. Lifesure offers a range of insurance products which cover personal insurance as well as commercial operations. Various levels of personal information will be required to perform this task.
If you require more information, our Data Protection Officer is Paul Reid. Please contact him as follows:
Data Protection Officer
Lifesure Group Limited
3 Fenice Court
What information do we collect?
We collect a range of information about you. This includes:
- Your name, address and contact details, including email address and telephone number
- 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 Lifesure needs to make reasonable adjustments during the recruitment process
- Information about your entitlement to work in the UK
- Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief
We collect this information in a variety of ways. For example, data might be contained in application forms, CVs, resumes, motivation letters, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment including online tests.
We will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. We seek information from third parties only once a job offer has been made and we will let you know that we are doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why do we process personal data?
We need to process data to take steps at your request before entering into a contract with you. We also need to process your data to enter into a contract with you.
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in the UK before employment starts (known as right to work checks).
We have a 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 to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
Where we rely on legitimate interests as a reason for processing data (when receiving applications or speculative approaches), we have considered whether those interests are overridden by the rights and freedoms of employees or workers and we have concluded that they are not.
We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.
Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.
For some roles, we are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.
Who has access to your data?
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team (which may include an outsourced service provider), interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff (which may be via an outsourced service provider) if access to the data is necessary for the performance of their roles.
We will not share your data with third parties, except for outsourced service providers with which we engage and where it is necessary for the performance of their roles.
We will share your data with your stated reference contacts which may include former employers, Universities and colleges to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
How do we protect the data?
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
How long do we keep data?
If your application for employment is unsuccessful, we will delete and destroy your data after a retention period of 6 months, following the recruitment process for the role. We must comply with a legal obligation placed on us to report on equality of opportunity and onboarding processes.
As a data subject, you have a number of rights. You can:
- Right of access – you have the right to request a copy of the personal data we have on you and ask for supporting information on why we hold it
- Right of erasure – in some circumstances, you have the right to request that we erase personal data about you. Please note, this is depending on the information we hold and our lawful reason to keep it – see retention periods
- Right of rectification – you have the right to request that we rectify inaccurate personal data about you
- Right to restrict processing – in some situations, you have the right to request that we do not use the personal data you have provided. Such situations could include where you believe that data held includes inaccuracies
- Right to object– you have the right to object to certain processing of your personal data, although overridden if Lifesure demonstrate the legitimate legal grounds for the processing of the data
- Right to data portability – you have the right to require us to provide you with a copy of your information for your use or transfer to another service provider.
If you would like to exercise any of these rights, please make a subject access request by contacting our Data Protection Officer.
If you believe that we have not complied with your data protection rights, you can complain to the Information Commissioner.
Will I be subject to automated decision making?
Your personal data may be subject to automated decision making when divergent (‘killer’) questions are used in the application process.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.