HR Privacy Policy

Rayner Careers Page Privacy Notice

Purpose and Scope

Rayner Surgical Group Limited and its subsidiary companies (Rayner) are responsible for deciding how we hold and use personal information about you. You are being provided a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). 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 provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR). Rayner is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

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.

What information does Rayner collect?

Rayner collects a range of information about you. This may include:

• 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 Rayner needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK or country of employment; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

Rayner may collect this information in a variety of ways. For example, data might be contained in CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests. Rayner may also collect personal data about you from third

parties, such as references supplied by former employer or from the Disclosure and Barring Service in respect of criminal convictions (see below). Rayner will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so. Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Information about Criminal Convictions

For certain roles, 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 – commercial roles require a clear report from the Disclosure and Barring Service for example. We will collect and process information about your criminal convictions history if we would like to offer you such roles (being conditional on checks and any other conditions, such as references, being satisfactory).

Why does Rayner process personal data?

Rayner will use the personal information we collect about you to:

• Manage the recruitment process;
• Assess your skills, qualifications, and suitability for prospective roles;
• Carry out background and reference checks, where applicable;
• Communicate with you about the recruitment process;
• Keep records related to our hiring processes;
• Comply with legal or regulatory requirements e.g. it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
• Process data to take steps at your request prior to entering into a contract with you.

Rayner has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. If your application is unsuccessful, Rayner may keep your personal data on file in case there are future employment opportunities for which you may be suited. Rayner will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information may 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. Rayner will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment (such processing will then be subject to the Rayner Group Employee Privacy Notice). Rayner will then share your data with former employers to obtain references for you. Your data may be transferred outside the European Economic Area (EEA) to other jurisdictions that Rayner operates.

How does Rayner protect data? 

Rayner takes the security of your data seriously. It has 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. 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. 

For how long does Rayner keep data? 

If your application for employment is unsuccessful, Rayner will hold your data on file for 12 months after the end of the relevant recruitment process N.B. 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 you agree to allow Rayner to keep your personal data on file, Rayner will hold your data on file for a further 24 months for consideration for future employment opportunities. At the end of that period or once you withdraw your consent, 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 employment record and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice. 

Your rights 

As a data subject, you have a number of rights. You can: 

• access and obtain a copy of your data on request, enabling you to receive a copy of the personal
  information we hold about you and to check that we are lawfully processing it;
• require Rayner to change incorrect or incomplete data, enabling you to have any incomplete or
  inaccurate information we hold about you corrected;
• require Rayner to delete or stop processing your data, for example where the data is no longer
  necessary for the purposes of processing or for processing that requires consent e.g. the use
  of your personal information for the purposes of the recruitment exercise. In such circumstances
  you have the right to withdraw your consent at any time; and
• object to the processing of your data where Rayner is relying on its legitimate interests as the
  legal ground for processing. If you believe that Rayner has not complied with your data
  protection rights, you can complain to the Information Commissioner.

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 HR Director in writing. 

What if you do not provide personal data? 

You are under no statutory or contractual obligation to provide data to Rayner during the recruitment process. However, if you do not provide the information, Rayner may not be able to process your application properly or at all. 

Automated decision-making 

You will not be subject to decisions that are based solely on automated decision-making. 

Data Protection Responsibility 

The Legal Director is responsible for overseeing compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your personal information, please contact the Legal Director. 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.