Saracens Ltd and our associated companies MBN Events, The UK Investor Show and E-Sports Awards (together the Premier Team Promotions Group) hold and process data on all current and former job applicants, speculative applicants and interview candidates, whose information you provide to us in connection with the recruitment process (e.g. name, address, date of birth, whether or not you have a disability).
We are the data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/279) and any other law applicable to the processing of your personal data. We will take all necessary steps to ensure that your personal data is processed by us in accordance with these data protection laws.
This privacy notice aims to give you information on how we collect and process your personal data through the recruitment process and your subsequent interactions with us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
- Processing of Personal Information
Saracens Ltd collects and processes your Personal Data for the purposes described in this Privacy Notice.
- What data do we process?
We may collect various types of Personal Data about you for the purposes described in this Privacy Notice including:
– Personal data (usually detailed on your CV) – Your title, forename, middle name(s) and surname, birth name, preferred name, any additional names, nationality, second nationality, date of birth, age, home contact details (e.g. address, telephone number, e-mail), your photograph;
– Data related to your employment and education history – Information included on your CV, including references, education history and employment history;
– Recruitment data – Interview and assessment data, Disclosure and Barring Service checks, vetting and verification information, documentation relating to your right to work in the UK, driving licence;
– Regulatory data – records of your registration with any applicable regulatory authority, your regulated status and any regulatory references;
– Remuneration and benefits data – your remuneration information in your current and past roles (including salary/hourly plan/contract pay information as applicable, allowance, bonus and merit plans);
2.2 Special categories of Personal Data
To the extent permitted by applicable laws we may also collect and process a limited amount of Personal Data falling into special categories, sometimes called “sensitive personal data”. This term includes information relating to such matters as racial or ethnic origin, religious beliefs, physical or mental health (including details of accommodations or adjustments), sexual orientation, information regarding sexual life, biometric data, criminal records and information regarding criminal offences or proceedings.
- How does Saracens Ltd collect data?
We collect and record your Personal Data from a variety of sources, but mainly directly from you. You will usually provide this information directly to our HR team by email, in your CV or in your application cover letter. The information may also be gathered in notes made by our recruiting manager during an interview. Further information will be collected directly from you if you are successful in securing the position. The employee privacy notice will be provided to you before we collect any additional data from you for the purpose of employing you.
We may also obtain some information from third parties, for example, employment agencies, references from a previous employer, medical reports from external professionals, tax authorities, benefit providers or where we employ a third party to carry out a background check (where permitted by applicable law).
One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not be able to process, or continue with (as appropriate), your application.
- What is the purpose and lawful basis for which data are processed?
We may collect and process your Personal Data for various purposes, as set out in this Privacy Notice.
Where applicable data protection laws require us to process your Personal Data on the basis of a specific lawful justification, we generally process your Personal Data under one of the following bases:
– the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract.
– the processing is necessary for the legitimate interests pursued by Saracens Ltd (being those purposes described in the section above), except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data;
– the processing is necessary for compliance with a legal obligation to which Saracens Ltd is subject;
We may on occasion process your Personal Data for the purpose of the legitimate interests pursued by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data.
We have identified the following purposes for processing Personal Information. These purposes each relate to a lawful basis for processing, as required under applicable law.
These purposes include:
|Purpose for processing||Type of data||Lawful basis|
|Recruitment and selection||CV’s, covering letters||This processing is necessary to take steps at the applicant’s request to enter a contract of employment.|
We will process such personal data on the basis that it is necessary to do so in order to perform the contract you enter into with us.
|Appropriate vetting for recruitment including, where relevant and appropriate, right to work verification, criminal record checks (if and to the extent permitted by applicable laws), relevant employment history, relevant regulatory status and professional qualifications;|
|Passports, Right to work documentation, DBS,|
Car insurance certificates
|This processing is necessary for the compliance with legal obligations to which Saracens Ltd is subject.|
This processing is also necessary for the purpose of the legitimate interests pursued by the Saracens Ltd in terms of the Safeguarding of vulnerable groups for which it has responsibility.
|To enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you;|
|This processing is necessary to perform the contract between you and Saracens Ltd and for the compliance with legal obligations to which Saracens Ltd is subject.|
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
4.1 Processing special categories of Personal Data or sensitive data
The sensitive or special categories of Personal Data that may be processed by Saracens Ltd are set out in this Privacy Notice. Where applicable data protection laws require us to process such special categories of Personal Data on the basis of a specific lawful justification, we process the same under one of the following bases:
– the processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or Saracens Ltd in the field of employment law, social security and social protection law, to the extent permissible under applicable laws;
– the processing is necessary for the assessment of your working capacity, medical diagnosis, or the provision of health care or treatment, to the extent permitted by applicable laws;
– the processing is necessary to protect your vital interests or of another person where you are physically or legally incapable of giving consent (for example in exceptional situations such as a medical emergency); or
– the processing is necessary for the establishment, exercise or defence of legal claims.
This may include the following, although this is not an exhaustive list:
|Purpose for processing||Lawful basis|
|Assess and review eligibility to work for Saracens Ltd in the jurisdiction in which you work (right to work)||This processing is necessary for the purposes of complying with a legal obligation as well as in the field of employment law. (Immigration,|
Asylum and Nationality Act 2006 (the 2006 Act))
|The collection of statistical data to keep the Saracens’ commitment to equal opportunity under review||This processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or Saracens Ltd in the field of employment law, social security and social protection law, to the extent permissible under applicable laws.|
(Equality Act 2010)
|Compliance with employment, health and safety or social security laws. For example to make reasonable accommodations or adjustments and avoid unlawful discrimination or dealing with complaints arising in this regard||This processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or Saracens Ltd in the field of employment law, social security and social protection law, to the extent permissible under applicable laws, such as Equality Act 2010.|
We may seek your consent to certain processing which is not otherwise justified under one of the above bases. If consent is required for the processing in question, it will be sought from you separately to ensure that it is freely given, informed and explicit. Information regarding such processing will be provided to you at the time that consent is requested, along with the impact of not providing any such consent. You should be aware that it is not a condition or requirement to agree to any request for consent from Saracens Ltd.
4.2 Processing data relating to criminal convictions and offences
Personal Data relating to criminal convictions and offences will only be processed where authorised by applicable laws and where it is appropriate for the role and to safeguard vulnerable groups. In these cases, we would carry out a Disclosure and Barring Service check (DBS) at the recruitment stage, however further information may be collected during your employment should you be successful in obtaining the role as in accordance with s10(1)(a) of the Data Protection Act 2018.
- Retention of Personal Data
Saracens Ltd endeavours to ensure that Personal Data is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as possible. The retention of your data will depend on whether you are successful in obtaining a role at Saracens Ltd.
If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for up to three months once the recruitment process ends to ensure we comply with our legal obligations in employment law.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for six months once the recruitment process ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
If your application is successful, your data will be kept and transferred to the systems we administer for our employees. We have a separate privacy notice for employees, which we will provide to you. However, some Personal Data may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.
- Security of data
Saracens Ltd uses a variety of technical and organisational methods to secure your Personal Data in accordance with applicable laws.
Saracens Ltd is committed to protecting the security of the Personal Data you share with us. In support of this commitment, we have implemented appropriate technical, physical and organisational measures to ensure a level of security appropriate to the risk.
- Your rights
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The law on data protection gives you certain rights in relation to the data we hold on you.
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Saracens Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 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 contact you to ask you for further information in relation to your request to speed up our response. If you wish to exercise any of these rights you can email our Privacy Officer who will be able to help you at email@example.com
We try to respond to all 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 each case, where we are legally entitled to take longer to respond). In this case, we will notify you and keep you updated.
Transfer of your personal data outside of the EEA
Saracens Ltd will not pass your personal data to third parties, nor will it be process anywhere outside of the EEA for the purpose of this privacy notice.
In the event that you wish to make a complaint about how your personal data is being processed by Saracens Ltd, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Saracens Ltd’s privacy officer.
The details for each of these contacts are:
Supervisory authority contact details Privacy Officer
Contact Name: Information Commissioner’s Office
Address line 1: Wycliffe House
Address line 2: Water Lane
Address line 3: Wilmslow Cheshire
Address line 4: SK9 5AF
Address line 5:
Changes to this Privacy Notice
Last updated September 2019