Data controller: mGage Europe Ltd, 10th Floor, The Tower Building, 11 York Road, London, SE1 7NX
Data protection officer: Denzil Tapsell-Gunner, EU Head of Legal (firstname.lastname@example.org)
As part of any recruitment process, mGage collects and processes personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, and when we may transfer your personal data outside of your home jurisdiction.
We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations. We will only use your personal data in accordance with the Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.
What personal data does mGage collect?
mGage collects a range of personal data 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 organisation needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK; and
mGage collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
We will also collect personal data about you from third parties, such as references supplied by former employers. The organisation will seek information from third parties only once a job offer to you has been made and will request your consent to do so.
Data will be stored in a range of different places, including on your application record, in HR management systems (HRIS) or the Applicant Tracking System (ATS) and on other IT systems (including email).
Why does mGage process personal data?
We need to process data to take steps at your request prior to entering 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.
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, we have considered whether or not those interests are overridden by the rights and freedoms of employees, workers or job applicants and has concluded that they are not.
If provided by the applicant, 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 may 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. The organisation will not use your data for any purpose other than the recruitment exercise for which you have applied.
Who has access to data?
Your personal data will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with former employers to obtain references for you, this will be done with your consent only. Your data may be transferred to countries outside the European Economic Area (EEA), this is to enable access by authorised US employees, this is generally limited to the job roles outlined in first paragraph above. Data is transferred outside the EEA on the basis of Privacy Shield and EU model clauses.
How does mGage protect data?
mGage takes 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. Controls and policies include:
- HR Data Protection Policy
- Restricted access to SharePoint to access HR electronic records
- Password protected access and defined user roles within the HRIS and ATS system
- Confidential shredding facilities for safe destruction of data
For how long does mGage keep data?
If your application for employment is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process. At the end of that period or if you make a request for us to delete your data sooner, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. Once you become an employee, the periods for which your data will be held will be provided to you in a new privacy notice.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require the organisation to change incorrect or incomplete data;
- require the organisation to delete or stop processing your data, for example where the data
is no longer necessary for the purposes of processing;
- object to the processing of your data where the organisation is relying on its legitimate
interests as the legal ground for processing; and
- ask the organisation to stop processing data for a period if data is inaccurate or there is a
dispute about whether or not your interests override the organisation’s legitimate grounds
for processing data.
If you would like to exercise any of these rights, please contact the Data Protection Officer.
If you believe that mGage has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.
Recruitment processes are not based solely on automated decision-making.