Data Protection Policy
WHAT IS THE PURPOSE OF THIS DOCUMENT?
John Queripel Associates Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are receiving a copy of this privacy notice because you are applying for work or being assessed for career development with a client company of ours. It makes you aware of how and why your personal data will be used, namely for the purposes of the assessment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018).
Our clients want to make informed decisions and focus on the most appropriate way in which to select and develop people and match their aspirations to career opportunities. We use competency-based interviews and psychometric instruments, and our practices follow the guidance provided by the British Psychological Society. This includes the application and interpretation of a range of valid and reliable psychometric instruments and reporting on our findings following candidate interviews. We and our associates are registered with the Association of Business Psychologists or the British Psychological Society and work within the professional and ethical standards of those bodies. They are also registered with the Health and Care Professions Council.
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 HOLD ABOUT YOU
In connection with your application, we will collect, store, and use the following categories of personal information about you:
- The information you have provided to us or our client company(s) in your curriculum vitae, application and other similar material;
- The outcome of an assessment of Cognition which deals with thinking styles and abilities;
- The outcome of online Personality-style questionnaires;
- Any information you provide in an interview with a psychologist who will give you feedback on your results and discuss your career development and future aspirations;
- Any information you have provided including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, etc.
- Kept securely.
We may also collect, store and use the following types of more sensitive personal information:
- Information about your age, gender, race or ethnicity, religious beliefs, sexual and cultural orientation and political opinions which you have provided.
- Information about your health, including any medical condition, health and sickness records which you have provided.
- Information about criminal convictions and offences which you have provided.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
- You, the candidate.
- Our client company, or if different, your current employer.
- Any recruitment agency.
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
- Assess your personality, thinking styles and abilities, and suitability for the role on these criteria.
- Give feedback to you on your results.
- Keep records related to our consultancy processes.
- Comply with legal or regulatory requirements.
It is in our client’s legitimate interests to decide whether to appoint you to a role, and they have appointed us as professional advisers for this purpose.
After conducting tests and assessing questionnaires and other materials, and conducting an interview/interviews, we will then process that information to produce a report for our client company. This report will be confidential to them.
Your personal data comprises the diagnostic material we collect and produce, and your rights lie in that diagnostic material.
If you fail to provide personal information
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
INFORMATION ABOUT CRIMINAL CONVICTIONS
We do not envisage that we will process information about criminal convictions
Why might you share my personal information with third parties?
We will only share your personal information with:
- Our Associates who are independent professionals registered with the Association of Business Psychologists or the British Psychological Society and work within the professional and ethical standards of those bodies. They are also registered with the Health and Care Professions Council. Data and reports may be shared with Associates who contribute to client assignments.
- The client company for whom the report is being prepared, to the extent that the information is relevant to the purposes of the report.
All our Associates 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.
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 ten years where you are an existing employee of a client company, or one year where you are not an employee and we are notified that you have not subsequently been employed.
We retain your personal information for these periods 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 assessment in a fair and transparent way. After these periods, 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.
We do not transfer your personal data outside the European Economic Area (EEA) other than to client companies who have requested the reports.
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 would also have the right to object if we were to process your personal information for direct marketing purposes; however, this is not something we would ever do.
- 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 John Queripel in writing at firstname.lastname@example.org
NO FEE USUALLY REQUIRED
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 could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
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.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
RIGHT TO WITHDRAW CONSENT
In order for us to commence the assessment process, you will have had to provide consent to us processing your personal information for this purpose. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact John Queripel. Once we have received notification that you have withdrawn your consent, we will no longer process your assessment and, subject to our retention policy, we will dispose of your personal data securely.
DATA PROTECTION OFFICER
John Queripel is our data privacy manager appointed 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 data privacy manager. 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.