Privacy notice for job applicants v1.0. Published Sept 2024. Review date Sept 2026.
Our Contact Details
Name: West Hertfordshire Teaching NHS Hospital Trust
Address: Trust Offices, Watford General Hospital, Vicarage Road, Watford, Hertfordshire, WD18 0HB
Website: https://www.westhertshospitals.nhs.uk
ICO registration number: Z5205111
Our hospitals:
Watford General Hospital, Vicarage Road, Watford, Herts, WD18 0HB. 01923 244366
Hemel Hempstead Hospital, Hillfield Road, Hemel Hempstead, Herts, HP2 4AD. 01442 213141
St Albans City Hospital, Waverley Road, St Albans, Herts, AL3 5PN. 01727 866122
We are the Data Controller for your information. The Data Controller decides why and how to use and share information.
Data Protection Officer contact details
Our Data Protection Officer is Nicola Bateman and is responsible for monitoring our compliance with data protection requirements. You can contact them with queries or concerns relating to the use of your personal data at westherts.
How do we get information and why do we have it?
We collect personal data from various sources during the recruitment process to ensure we select the best candidates for our roles. Here’s how we gather this information and the reasons for having it.
- Application forms: When you submit your application through our online portal, we collect the information you provide, including your personal details, employment history, and qualifications.
- CVs and cover letters: Your CV and cover letter may contain additional information about your skills, experience, and motivations, which we review as part of the application process.
- Interviews: During interviews, we may collect further insights about your qualifications, experiences, and suitability for the role through your responses and interactions with our interviewers.
- References: We may request references from previous employers or other contacts to validate your employment history and character.
- Background checks: If applicable, we may conduct background checks, which could include verifying criminal convictions, to ensure the safety and integrity of our working environment.
Why we have your information
- Assessment of suitability: We collect and process this information to assess your qualifications and suitability for the position you have applied for. This helps us make informed hiring decisions.
- Legal compliance: Certain roles may require us to verify your identity and conduct background checks to comply with legal and regulatory requirements, especially in relation to safeguarding and patient safety.
- Enhancing our recruitment process: By collecting detailed information, we aim to improve our recruitment processes, ensuring we select candidates who align with our values and meet the needs of our patients and staff.
- Communication: Your contact information allows us to communicate with you about your application status and any next steps in the recruitment process.
- Record-keeping: We maintain records of applicants to comply with employment regulations and for future recruitment considerations.
By collecting this information, we aim to ensure a fair and efficient recruitment process while protecting the rights and interests of all candidates.
What information do we collect?
During the recruitment process, we collect various types of personal information to assess your suitability for the positions you apply for. The following outlines the types of personal information we may collect:
Personal information
- Name
- Contact details (address, phone number, email address)
- Previous employers
- Job titles and responsibilities
- Dates of employment
- Reasons for leaving.
- Qualifications and certifications
- Educational institutions attended.
- Dates of attendance
- CVs and resumes
- Cover letters.
- Personal statements
- Contact information for professional references.
- Feedback or evaluations from referees (if provided)
- Any other information you choose to provide that is relevant to your application, such as skills, interests, or volunteer experiences.
We collect this information directly from you through your application and interview process, as well as from third-party sources (such as references or background checks) when necessary. This information helps us evaluate your qualifications, conduct due diligence, and ensure a safe and compliant work environment.
More sensitive information
During the recruitment process, we may collect the following sensitive personal data:
- Criminal convictions: Information about any criminal convictions or offenses, which is essential for roles that involve working with vulnerable populations or require compliance with regulatory standards.
- Health information: If applicable, we may gather health-related information to accommodate special needs during the recruitment process or assess your fitness for specific roles that have health-related requirements.
- Equal opportunities data: We may ask for information regarding your ethnicity, gender, disability status, and other characteristics for equal opportunities monitoring purposes. Providing this information is voluntary.
- Voluntary sensitive data: Any additional sensitive personal data you choose to share during the application process, such as details about your religious beliefs or other personal circumstances.
- Requests for adjustments: Information regarding any reasonable adjustments you request during the application or interview stages, including those related to safeguarding.
Additionally, we will process the following information about you as part of the recruitment process:
- Selection information: This includes correspondence, interview notes, and results from any assessments you undertake.
- Pre-employment checks: We will conduct various checks, including:
- Identity verification and Right to Work confirmation.
- Professional registration and qualification checks
- Reference checks
- Work health assessments and Disclosure and Barring Service (DBS) checks.
If you disclose a disability and request consideration under the Disability Confident Scheme, your application will be reviewed to ensure you meet the essential criteria for shortlisting. If you do, you are guaranteed an interview. This disclosure is entirely optional, and you may choose not to share your disability status with the interview panel.
You may also request reasonable adjustments for the interview process; if you do, only the adjustments will be communicated to the panel, not your disability status. Additionally, you will have the option to provide equal opportunities information, which is not mandatory and will not affect your application if you choose not to disclose it.
As part of the selection process, you may be invited to participate in assessment days, complete tests, or undertake occupational personality questionnaires. Information will be generated by both you and us during this process, such as written tests or interview notes, and will be held according to our records retention schedule.
If we extend a conditional offer of employment, we will request additional information to conduct pre-employment checks, which include:
- Proof of identity: You may need to present original documents in person or submit them via our secure digital platform.
- Proof of qualifications: Similar to identity verification, you may be asked to provide original documents.
- Criminal records declaration: You will need to declare any unspent convictions.
- Criminal record check: This will be conducted via the Disclosure and Barring Service or Access NI to verify your declaration.
- References: We will contact your referees using the details provided in your application.
- Health questionnaire: You will be asked to complete a health questionnaire to determine your fitness for work.
- Reasonable adjustments: We will inquire about any reasonable adjustments you may need under the Equality Act 2010, which will be shared with relevant staff to ensure they are in place upon your employment.
If we extend a final offer, we will also require the following:
- Bank details: To facilitate salary payments.
- Emergency contact information: To know who to contact in case of an emergency at work.
- Pension scheme membership: Details about any pension scheme you are a member of.
For candidates transferring from another NHS organisation, we will request additional information from your current NHS employer via the ESR interface, including your mandatory training records and vaccination status.
We are committed to handling your sensitive personal data with the utmost care and in accordance with data protection laws. This information is collected solely for recruitment purposes, ensuring compliance with legal obligations and fostering an inclusive workplace.
Who do we share information with?
The information you provide as part of your job application will be accessible to staff members involved in your recruitment within the Resourcing and HR Team. Members of the shortlisting and interview panel will only have access to portions of your application that do not contain personal, sensitive, or monitoring information. They will also be able to view references for candidates they prefer. If you are successful after the interview, the Recruiting Manager will have access to your complete recruitment file.
During your recruitment and ongoing employment with the Trust, information about you may be gathered and shared from various sources, including:
- Current and previous employers: This may include any educational institutions if necessary.
- External organisations: Third parties acting on our behalf in the recruitment selection process.
- Medical and occupational health professionals: To assess your fitness for work and determine any reasonable adjustments you may need.
- Disclosure and barring service (DBS): If your role requires a DBS check, this will disclose any criminal convictions you may have. Not all roles necessitate a DBS check.
- Referees: Providing confidential insights about your suitability for the role. If a reference is provided "in confidence," it will not typically be shared with you without permission.
- Inter authority transfer (IAT): Information held by your previous NHS employer.
- HM Revenue and Customs (HMRC): Information regarding your pay and employment.
- Right to work and visa applications: Information pertinent to your eligibility to work.
- Pension information: Relevant when transferring within the NHS.
- Performance and work-related matters: Information from your manager/referee concerning your performance, sickness absence, and other related topics.
- Professional registration confirmation: Verification of your registration with relevant professional bodies.
- Other organisations: Any other entity that has a legal right to access your information.
- Data processors: We may engage organisations that act on our behalf and under our authority. These processors perform technical functions, such as providing systems that store information. We do not permit these processors to use your information for their own purposes or to connect it with other personal data they may have.
The categories of our processors include organisations that:
- Provide our IT systems.
- Manage the platforms used to process your application.
- Handle the disposal of confidential waste (e.g., paper records, laptops, or other IT equipment).
- Deliver certain recruitment services.
- Offer identity verification services.
We do not share any of the information you provide with third parties for marketing purposes. All third parties are contractually obligated to protect the data and only process it according to your instructions.
What is our lawful basis for using information?
Personal information
Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for using personal information is:
- Article 6(1)(b) processing necessary to perform a contract or to take steps at your request, before entering a contract.
More sensitive data
Under UK GDPR, the lawful basis we rely on for using information that is more sensitive (special category):
- Article 9 (B) Employment, social security, and social protection.
Part 2 Substantial public interest conditions – 9 Racial and ethnic diversity at senior levels of organisations.
If you provide us with any information about reasonable adjustments you require under the Equality Act 2010, the lawful basis we rely on for processing this information is:
- Part 2 Substantial public interest conditions - 8 Equality of opportunity or treatment.
We may also process some health data under UK GDPR -
- Article 9(2)(h) processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment.
The lawful basis we rely on to process any information you provide as part of your application or subsequent pre-employment checks, which is special category data, such as religious or ethnicity information or biometric data, under UK GDPR, is:
If we identify fraudulent or suspicious activities as part of identity check, we may share information with the police under UK GDPR –
- Article 9(2)(g) – Substantial Public Interest: This can be used when there is a substantial public interest in sharing the data to prevent or detect crime.
- Paragraph 14 of Schedule 1 of the Data Protection Act 2018 (DPA 2018) allows for the processing of special categories of personal data and criminal convictions data when necessary for the purpose of preventing fraud, under the condition of "substantial public interest." This paragraph is part of the substantial public interest conditions outlined in Part 2 of Schedule 1 of the DPA 2018.
We process information about job applicant criminal convictions and offences. The lawful basis we rely on to process this data are UK GDPR –
- Article 6(1)(c) legal obligation and Article 9(2)(b) legal obligations
How do we securely store your personal information?
We are committed to ensuring the security of your personal data. We have implemented appropriate technical and organisational measures to protect the data you provide to us from unauthorised access, use, alteration, disclosure, or destruction. These measures include:
- Encryption: We encrypt personal data both at rest and in transit to prevent unauthorised access.
- Access controls: Access to your personal data is restricted to authorized personnel involved in the recruitment process. We use secure authentication methods to control access.
- Data anonymisation: Where possible, personal data is anonymised or pseudonymised to reduce the risk of identification.
- Security audits: We regularly review our data security practices and perform system audits to ensure the safety of your information.
If there is a data breach that compromises your personal data, we will notify you and the Information Commissioner’s Office (ICO) in accordance with our legal obligations.
How long will we keep your data?
We will keep your personal data in line with the retention periods detailed in the NHS retention schedule.
Successful applications will remain in the e-recruitment system for 200 days after start date, but only information relevant to the employment of successful candidates will be retained within staff employment records.
For non- successful applications, personal information in the e-recruitment system will be deleted after 400 days from the application submission date. For further information, please contact the Recruitment Team: westherts.recruitment@.nhs.uk
What are your data protection rights?
Data protection laws give you several rights over your personal data. These rights are detailed below.
- Your right to be informed The Trust is required by law to provide you with information about how it collects and uses your personal data. The trust, by way of this privacy notice is providing you with this information.
- Your right of access You have the right to access personal information we hold about you. To access personal information we hold, please contact the recruitment team at: westherts.
recruitment @nhs.net
- Your right to rectification You have the right to have inaccurate information about you corrected or incomplete information completed. To update your application details, please login to the platform you applied on or email the recruitment team. westherts.
recruitment @nhs.net
- Your right to erasure You can request the deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (if applicable).
- Your right to restrict processing. You have the right to restrict the processing of your personal data in certain circumstances. This means that you can limit the way we use your data. This is an alternative to requesting the erasure of your data. The right is not absolute and only applies in certain circumstances.
- Your right to data portability You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request the transfer of that data to another data controller when technically feasible in certain circumstances.
- Your right to object You have the right to object to the processing of your personal data based on legitimate interests or public tasks, unless we can demonstrate compelling legitimate grounds for processing that override your rights.
- Your right in relation automated decision making and profiling. The trust does not use automated decision making and profiling for recruitment purposes.
Please contact westherts
Contacting us if you have a complaint or concern
We try to meet the highest standards when collecting and using personal information. We encourage people to bring concerns to our attention and we take any complaints we receive very seriously. You can submit a complaint by contacting our Information Governance team by emailing them on: westherts.
If you remain dissatisfied with the Trust’s decision following your complaint, you may wish to contact:
Information Commissioner’s Office
Wycliffe House Water Lane
Wilmslow
Cheshire
SK9 5AF