Candidate Privacy Notice
Victrex plc and its Group companies are "data controllers".
This means that we are responsible for deciding how we hold and use personal information about you. You are being notified of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor).
We want to make 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 provides you with certain information that must be provided under the Data Protection Act 2018 (UK) and General Data Protection Regulation (EU 2016/679) (GDPR) (EU) (the 'Data Protection Legislation').
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 to join Victrex, we will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter.
- The information you have provided as part of the application and submission process, including through our website/Linkedln or any other platform or process used by Victrex. This information may include your name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications.
- Any information you provide to us during an interview including recordings from video interviews.
- If applicable, the results of technical and/or psychometric tests taken as part of the recruitment process.
We may also collect, store and use the following types of special categories of personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about candidates from the following sources:
- You, the candidate.
- Recruitment agencies, from which we collect the following categories of data: CV, name, address, personal email address and contact details.
- Named referees, from whom we collect the following categories of data: dates of employment, position held, leaving reason and any other useful information which the referee deems it appropriate to provide.
- We may in the future as a growing organisation use a third party background check provider, from which we would collect the following categories of data: title, full name, previous names (if applicable), date of birth, gender, nationality, national insurance number, contact numbers, current address, address history, town of birth, country of birth, mother's maiden name, details of criminal convictions, passport number, driving licence number, previous employment details and adverse financial details.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly we will use your personal information in the following circumstances.
- Where we need to perform the employment contract we are about to enter into or have entered into with you (Contract).
- Where we have obtained your consent for processing your personal data (Consent).
- Where it is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests (Legitimate Interests).
- Where we need to comply with a legal obligation (Legal Obligation).
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role (Legitimate Interests and Contract);
- Carry out background and reference checks, where applicable (Contract and Consent);
- Communicate with you about the recruitment process (Legitimate Interest);
- Keep records related to our hiring processes (Contract and Legal Obligation);
- Comply with legal or regulatory requirements (Legal Obligation).
It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role. We will also need to process your personal information to decide whether to enter into a contract of employment or services with you.
Having received your CV and covering letter or your application form together with the results from the test which you took (if applicable), we will then process that 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. We will use the information you provide to us at the interview to decide whether to offer you the role.
If we decide to offer you the role, we will then undertake the necessary pre-employment checks which consist of identity, right to work and referencing checks. We may, should your role require it, conduct financial probity and basic DBS checks with a view to having all checks completed prior to commencement of employment.
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.
How we use special categories of personal information
We will use your special categories of personal information in the following ways:
- We will use 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 a test or interview.
- 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
We envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:
- Various roles within our business require a high degree of trust and integrity since it involves dealing with sensitive commercial, personal and product information and so we may 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.
We may utilise online candidate testing and assessments. The results of these assessments are reviewed by our recruitment team who will decide whether to progress or reject your application. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information for the purposes of processing your application.
At the date of issue of this Candidate Privacy Notice, our application system in part is managed by a company called Teamtailor AB. They are a data processor who we may instruct to manage candidate applications and operate on behalf of Victrex. Teamtailor AB are based in Sweden and will share personal data with Victrex staff including Hiring Managers and HR employees responsible for recruitment who require access to this information to administer your application and for the purposes noted above.
In addition to this platform we may engage third party providers for technical assessments, personality tests and psychometric testing including game based testing applications, in order to assess suitability for certain roles. In the event that we do engage third party providers for this purpose, these are provided to us by Alva Labs AB and Arctic Shores. These suppliers are both processors and joint controllers with us of your personal information when carrying out the assessments.
We may also use the supplier Willo Technologies Limited to provide a video interview platform in order for us to assess your suitability for a role. Willo Technologies Limited are data processors who we may instruct to provide a platform to invite you to an online interview.
Where we share your data with third party suppliers we require them to take appropriate security measures to protect your personal information and to process your personal information for specified purposes in accordance with our instructions.
We will share your information with our Victrex recruitment staff including hiring managers and HR employees responsible for recruitment.
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 the Victrex Legal Team.
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 six (6) months after we have communicated to you our decision about whether to appoint you to 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 our data retention policy.
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 particular situation which makes you want to object to processing on this ground.
- 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 either the Human Resources Team or the Legal Team in writing.
Where you are a candidate applying for a role with us you have the right to make a complaint at any time to the supervisory authority in the region in which you are based but we would always appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact either the Human Resources Team or the Legal Team in the first instance.
Right to withdraw consent
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact either the Human Resources Team or the Legal Team. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our data retention policy, we will dispose of your personal data securely.
Version 3 November 2021
For questions, further information about our handling of personal data or for contact with us in other matters, please use the below stated contact details;