ForrestBrown Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor) including where you are applying for a role delivering services to our subsidiary company ForrestBrown Global Services Limited. . 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 also provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR).
Data Protection Principles
We will comply with data protection laws 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 (in your case this is recruitment).
- accurate and kept up to date.
- kept only if necessary for the purposes we have told you about.
- kept securely.
On what basis will we process your personal data?
When you first come into contact with us, we will process your data for legitimate business interests. This means the interests of ForrestBrown Limited, ForrestBrown Global Services Limited (where applicable), and our parent company alliantgroup LP in carrying on a research and development (“R&D”) tax consultancy business. For example, it is in our legitimate interests to assess your application and decide whether we might wish to appoint you to the role since this is beneficial to our business.
Legitimate interests can also apply to the processing of data that is in your interests. For example, you only wish to spend time applying for a role with us if your skills match our requirements.
When we process your personal information, we make sure we consider and balance any potential impact on you (both positive and negative) and your rights under data protection laws. We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
The kind of information we hold about you
We will collect, store, and use the following categories of personal information about you in connection with your application for work with us:
- the information you have provided to us in your CV and covering letter;
- the information you have provided to via our website application form, including your name, title, telephone number, personal email address, most recent job title, employment history and qualifications;
- any information you provide to us during an interview or otherwise; and
- any other information you may provide us with during the pre employment screening process, for example, referee details, details of unspent convictions and, where applicable, a Disclosure Barring Service certificate.
We may also collect, store and use the following types of more sensitive personal information:
- information about your health, including any medical condition, health and sickness records;
- information about your race or ethnicity, religious beliefs, sexual orientation and political opinions (collected for monitoring purposes only); and
- information about criminal convictions and offences whether via voluntary disclosure off unspent convictions or, where required by the role, via a Disclosure Barring Service certificate.
How is your personal information collected?
We collect personal information about candidates from the following sources:
- you, the candidate;
- any recruitment agency, who you have instructed to represent you;
- any recruitment website that you have applied through;
- your named referees, from whom we will collect confirmation of your dates of employment, the role you undertook and who we will ask for comments about your performance;
- if relevant to the role for which you are applying, a credit reference agency from which we will collect information about your credit history;
- any information available in a public professional forum such as LinkedIn.
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 our legal or regulatory requirements.
We also need to process your personal information to decide whether to enter into a contract of employment with you.
Having received your application, we will process your personal information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview and otherwise to decide whether to offer you the role. If we decide to offer you the role, we will then undertake our pre employment screening checks.
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 will not be able to process your application successfully. For example, if we require to undertake a credit check for the 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 will use your particularly sensitive personal information in the following ways:
- we will use any 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 your interview or any assessment we make ask you to complete.
- we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
If you are offered a role with us, you will be asked to make a voluntary disclosure of any unspent criminal convictions related to theft, fraud, deception, or offences related to cybercrime. Evidence of prior convictions will only be considered to the extent that the conviction is relevant to the risks associated with the performance of the role for which you are applying or where it will, or may, have a material adverse impact on ForrestBrown’s reputation as an R&D tax credit provider.
If we offer you a role which requires a high degree of trust and integrity, for example in the finance team (which involves dealing with client money), instead of asking for voluntary disclosure we will ask you to seek a basic disclosure of your criminal records history.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Data sharing
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application:
- our ultimate parent company, alliantgroup LP;
- where you are applying for a role deliverying services to them, ForrestBrown Global Services Limited;
- the providers of our IT systems (including our recruitment database providers, Eploy (which is a trading name of ITS Software Systems Ltd)); and
- our professional support service providers.
All our third-party service providers and our parent company 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.
International Transfers
We may share your personal data with our ultimate parent company, alliantgroup LP who are based in the US including with our US based recruitment team. This will involve transferring your data outside the United Kingdom (UK).
Many of our external third-party service providers (for example Amazon Web Services and GoogleApps) are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by using specific contracts approved by the ICO which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security
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 Sarah Rogers, Talent Acquisition Manager.
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.
Data Retention
We will retain your personal information collecting for monitoring purposes for 6 months after which it will be anonymised
Data relating to unsuccessful candidates will be retained for 6 months after we have communicated to you our decision about whether to appoint you to the 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 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 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 Privacy Manager in writing.
Data Privacy Manager
We have appointed a data privacy manager 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 them.
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.
Updated 1 March 2022