Privacy Policy.

Introduction.

Please select below the relevant privacy policy for your area of interest

The way in which Vero handles your personal data will vary dependent upon whether you are: a Client or a visitor to our website; a Candidate currently going through a screening process with us; an employee of Vero; or an applicant for a role with Vero. Please select the relevant privacy policy from the menu below for further information.

Introduction

Vero Screening Ltd (Vero Screening) is a limited company incorporated in England and Wales (Company number 05392085).

We provide pre-engagement and in-engagement screening services to our clients.
This privacy policy is aimed at prospective or existing clients and visitors to the company website. All references to our ‘website’ throughout the privacy policy refers to the company
website https://veroscreening.com/. This privacy policy does not apply to personal data we collect on Vero Screening employees or on individuals going through the screening process at the instruction of our client.

If you are currently being screened by Vero Screening and would like further details regarding the handling of your personal data in this context, please refer to our ‘Privacy policy for Candidates’.

If you are an employee of Vero Screening please refer to our ‘Privacy policy for employees’

If you have questions regarding your personal data and how we use it, please contact our Data Protection Officer using the contact details below:

Data Protection Officer
Vero Screening Ltd
Princes House
Brighton
East Sussex
BN1 3XB
United Kingdom
Tel: +44 (0) 1273 840 800
Email: dpo@veroscreening.com

Overview

  • How we collect your personal data;
  • The types of personal data we collect on our website;
  • Information gathered to manage our relationship with our clients;
  • Information gathered as part of sales and direct marketing activity;
  • Information gathered during employment screening on behalf of our clients;
  • Automated decision making or profiling using personal data;
  • Data security; Data retention; Data transfer; Data sharing; Data subject rights.

How we collect your personal data

We collect your personal data in a number of ways which are listed below:

  • When we have contact with you:
  • When we speak to you on the phone;
  • When you email us;
  • When you send information to us through the post
  • When you visit our website
  • From our clients, in the delivery of our contractually agreed services
  • From third parties (eg accredited providers of direct marketing lists)
  • From publicly available sources

When we collect your data

  • When we collect your data
  • When you navigate around our website
  • When you contact us via the ‘Contact Us’ form on our website
  • When you communicate to us through instant messaging (eg Tawk)
  • When you ‘sign up’ to our news letter
  • When you apply to one of our advertised positions

Personal data we obtain from you or your personal computer

  • Cookies.
  • Name; email; company; contact number; reason for contact.
  • Any information provided by the data subject in the free text box; IP address/location; Referral URL
  • Email address
  • Contact information; address information; CV attached / cover letter; employment status; right to work; optional equality and diversity questions for the purpose of establishing special arrangements or equal opportunities monitoring.

Why we collect this data

  • To improve user experience.
  • To contact you in response to your question. To understand your question and reply to you.
  • To understand your question and reply to you. To better understand use of our website.
  • To send you our newsletter.
  • To contact you in relation to the position, or similar positions. To review your experience for suitability for a role. To confirm potential notice periods. To comply with legislation.

Lawful basis for gathering information

  • Our legitimate interests to improve website performance.
  • Your consent to be contacted in respect to your query.
  • Our legitimate interests to improve website performance, and user experience.
  • Our legitimate interests to market/ advertise our services to customers. Your consent by signing-up to our newsletter.
  • Our legitimate interests to advertise for open opportunities at Vero. Your consent by applying for an open position or expressing interest in a role.

Third party website applications

Vero use a messaging tool allowing for instant communication between users of our website and Vero. The provider of this service is ‘Tawk’ and their privacy policy can be viewed at https://www.tawk.to/privacy-policy/. The type of data processed and lawful basis for processing are expressed in the previous table ‘When you communicate to us through instant messaging’.

Information gathered as part of sales and direct marketing activity

Vero Screening maintain a marketing list and occasionally send direct marketing communications to relevant parties (such as HR, procurement) at businesses who might be interested in the services we provide, or updates relevant to the screening industry. The personal information that is maintained to facilitate direct marketing is typically limited to full name and email address.

The lawful basis for Vero’s direct marketing activity is the express consent of the individual to receive such communications. Where you no longer wish to receive such communications from Vero you can either select the unsubscribe option (which is present on all marketing emails), or request to be removed from Vero’s direct marketing lists. To be removed from Vero’s direct marketing list please notify the Sales Team and ask for your information to be removed from our records (https://veroscreening.com/contact-us/).

Information during screening on behalf of our clients

If you are undergoing screening on behalf of one of our clients, please refer to our ‘Privacy policy for Candidates’

Automated decision making or profiling using personal data

Vero Screening do not carry out automated decision making, or profiling using personal data.

Data security

Vero Screening takes its obligation to maintain the privacy of your personal data seriously and are certified to both ISO27001:2013 and Cyber Essentials. As a UK based company (acting as a Data Processor on behalf of our Clients) we are compliant with the General Data Protection Regulation (GDPR) and UK Data Protection legislation. We observe strict technical and organisational measures to safeguard the secure collection, processing, use and storage of personal data, in line with relevant legislation.

Data retention

Vero Screening will only retain personal data for as long as necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Following this all personal information will be securely deleted from our records.

Links to other websites

Our website may contain links and icons which enable you to visit other websites which may be of interest. However, once you have used these to leave our website, we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites. You should exercise caution and look at the privacy statement (see below) applicable to the website in question.

Data Transfer

Vero Screening’s servers are based within the European Economic Area (EEA). No personal data that is processed or collected by using this website will be transferred or stored outside the European Economic Area by Vero Screening.

Data sharing

Vero Screening do not share the personal data that is processed or collected by using this website with any third parties or use such data for any purposes other than what is outlined in this privacy policy.

Data subject rights

UK and European Data Protection legislation gives you (as a data subject) rights which include:

  • the right to information;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to request data portability; and
  • the right to object to processing.

You also have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note some restrictions may apply to the applications of the rights. For further details, please refer to the information provided on the website of The Information Commissioner https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/. Should you wish to exercise one of your rights under UK and European Law please direct your request to our Data Protection Officer whose contact details are provided in the Introduction of this privacy policy for website users.

Right to Complain

You have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office, please refer to its website at www.ico.org.uk. You may contact the Information Commissioner’s Office as follows:

By email: Please complete the form at https://ico.org.uk/global/contact-us/email/

By phone: 0303 123 1113

By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Updates and Further Information

This Privacy Policy was updated on 2019-12-19. It may be updated to take into account changes at Vero Screening or for example to reflect changes to regulation or legislation.

Updates to this Privacy Policy will be posted on this page – please check back from time to time.

Vero Screening Ltd

19 December 2019

Introduction

Vero Screening Ltd (Vero Screening) is a limited company incorporated in England and Wales (Company number 05392085). We provide pre-engagement and in-engagement screening services to our clients. Full details of the services we provide can be found in the Service Descriptions section of our website https://veroscreening.com/pre-employment-screening/services/descriptions/.

This Privacy policy for Candidates gives you detailed information on when and why we collect your personal data, how we use it and how we keep it secure. Vero Screening processes your personal data on behalf of our client. Any client of Vero Screening that engages Vero Screening to perform screening services in relation to you is the data controller of your personal data. Vero Screening is the data processor of your personal data and is committed to protecting your personal data.

If you have questions regarding your personal data and how we use it, please contact our Data Protection Officer using the contact details below:

Data Protection Officer
Vero Screening Ltd
Princes House
Brighton
East Sussex
BN1 3XB
United Kingdom

Tel: +44 (0) 1273 840 800
Email: dpo@veroscreening.com

Overview

  • Lawful basis for processing
  • How we collect your personal data
  • The types of personal data we collect
  • Why we collect your personal data and how we use it
  • Change of purpose
  • How we handle your personal data
  • How we protect your personal data
  • Your rights as a data subject
  • Updates and further information

We collect your personal data in a number of ways which are listed below:

  • When you provide personal information to us through our online Candidate portal
  • When we have contact with you:
    • When we speak to you on the phone;
    • When you email us;
    • When you send information to us through the post
  • When you visit our website. From our client who requires your screening to be conducted
  • We may also get personal data about you from third parties – please see the ‘Why we collect your personal data and how we use it’ section for more details.

Lawful basis for processing

Our client is responsible for determining the lawful basis for your screening. The collection of your personal data is done in accordance with their instructions. Separately, Vero will ask for your signed authorisation. This authorisation is required to facilitate the screening process by enabling us to process your data and procure information from relevant parties. Typically these relevant parties (organisations and referees) will not share your information unless we can demonstrate our request is made with your knowledge and agreement. This authorisation does not alter the lawful basis for processing determined by our client. Furthermore, should you withdraw or withhold this authorisation it will have no bearing on our client’s lawful basis for screening.

If your offer of a role is dependent upon successfully undergoing screening (or if screening is required under your existing contract) then failure to authorise Vero to process your personal data for screening purposes may have implications on your contractual relationship with our client. Vero are not involved in any decisions relating to your contractual relationship with our client and can take no responsibility for any actions taken by our client in connection with the screening process.

Should you have any questions in relation to the consequences of withholding your personal data and / or withholding or withdrawing your authorisation in connection with the screening process you should make contact with your HR Representative at our client.

The types of personal data we collect

The type of personal data we collect depends on where and when it is gathered and for what purposes we have gathered it:

Personal data we obtain from you

When you complete your screening questionnaire via our online Candidate portal we will collect information from you in order to provide our services to our clients.

Subject to the level of screening and types of checks required by our client, we may collect the following information (and/or relevant documentation to evidence the following information):

  • Prefix and name (current and former)
  • Gender
  • Contact email address
  • Date of Birth
  • Place of birth
  • Nationality
  • Contact phone number(s)
  • Education details (including gaps)
  • Employment details (including gaps)
  • Current address
  • Address history
  • Photographic proof of identity
  • Financial integrity information
  • Criminal history
  • Civil court record
  • Professional qualifications
  • Regulatory information
  • References
  • Government-issued identity records/numbers
  • Right to work information
  • Directorship information
  • Driving history/and insurance details
  • Fitness and propriety questions

Personal data collected when you visit our website

Full details of the personal data Vero collects and processes when you visit our website are provided in our General Privacy Policy

 

Information we obtain independently from you

As part of the screening process our client requires Vero Screening to verify the information that you have provided to us and conduct the checks (services) required for the screening. Vero Screening has a services description page which can be seen at www.veroscreening.com/resources/services-descriptions/.

It is important to note that not all screenings require the same levels of checks and verifications. Should you wish to know more as to the required checks or verifications relating to your screening, we recommend you contact the relevant HR contact at the client who instructed Vero Screening to carry out the screening exercise.

Vero Screening has no control as to the exact information returned during a screening, and as a result cannot anticipate what information may be returned from a third-party source. As a data processor Vero Screening does not provide any opinion or make any decisions on what to report to our client, and therefore only provides the information in an objective manner. Our client (as data controller) is responsible for how it interprets the information.

The sources of information Vero Screening might use as part of a screening could include:

  • Our client;
  • Publicly available registers/sources of information such as print media archives, government watch or sanctions lists;
  • Referees (including reference providers) such as previous institutions where you have studied, worked, are currently (or were previously) a director, obtained a professional qualification, have a professional membership with, your accountant to confirm periods of self-employment, job agencies to confirm periods of non-employment;
  • Regulatory bodies who can confirm periods of registration, approval or disciplinary history;
  • Credit reference agencies, bankruptcy databases or lists for the purposes of establishing financial integrity;
  • Civil court records (to confirm whether you have has been subject to adverse proceedings);
  • Directorship registers or holders of such information;
  • Relevant government agencies such as licensing authorities who can confirm details pertinent to the employment screening process;
  • Law enforcement agencies or bodies who maintain criminal history information (such as the Disclosure Barring Service for the UK), courts, police departments;
  • Our trusted network of third party suppliers to enable your personal data checks to be completed in jurisdictions outside of the UK or in areas outside of our expertise.

Why we collect your personal data and how we use it

As previously stated in the ‘Lawful basis for processing’ section of this policy, our primary function is as a service provider to our clients, conducting the following types of services:

  • Background screening of individuals before and during employment, volunteer or contractual relationships.
  • Collection, validation and storage of on-boarding and other human resources documents.

We use your personal data in the following ways:

  • To carry out our business and to provide our services to our clients.
  • To keep the client updated of the progress of your screening or produce relevant reports for the client in relation to the screenings they have requested.
  • To enable you to maintain a profile on your account which you can amend or delete

Where applicable we may share your personal data with our trusted network of third party suppliers, to enable your personal data checks to be completed in jurisdictions outside of the UK or in areas outside of our expertise.

Change of purpose

We will only use your personal data for the purposes for which we collected it (ie screening purposes as instructed by our client). Please note we may process your personal data without your knowledge or consent, where this is required or permitted by law.

How we handle your personal data

We may share your personal data with some of our suppliers who perform services on our behalf. We make sure anyone who provides a service for Vero Screening enters into an agreement with us and meets our standards for data security. They will not use your personal data for anything other than the clearly defined purpose relating to the service that they are providing. We may share your details with:

  • Suppliers who work on behalf of Vero Screening for the performance of any contract we enter into with them (eg to check your credentials and references in countries outside the UK).
  • Where required to do so, for example when requested by the police or a regulatory or government authority investigating illegal activities.

How we protect your personal data

Vero Screening is committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected from unauthorised access and improper use.

Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For further details please see our ‘Data Protection Guide for Candidates’. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify our clients and any applicable regulator of a breach where we are legally required to do so.

As part of the services we offer to our clients, the personal data you provide may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen if we are asked by our client to check your references for time spent working outside of the EEA and we engage a service provider based in the appropriate jurisdiction to perform the checks on our behalf. If Vero Screening transfers your personal data outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

Vero Screening recognises that some countries do not have the same standard of data protection afforded in most EU States, for this reason Vero Screening has a strict supplier management policy which includes the screening of all new suppliers, annual security questionnaires and reviews, and the use of formal processing agreements. Our processing agreements also include terms dictating that the suppliers:

  • are only permitted to process your personal data for employment screening purposes;
  • can only retain your personal data for a maximum period of 90 days (unless they are restricted by law from doing this) following which they must securely delete such records;
  • must immediately notify Vero Screening of any suspected or actual data breach of your personal data;
  • shall take all appropriate technical and security measures to safeguard your personal data; and
  • will only transfer your personal data in accordance with approved data transfer provisions.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, as determined by our client, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In relation to the screening report and information gathered during the course of the screening, our client specifies the required data retention period for electronic/paper records. Subject to our legal and regulatory requirements, our screening platform will securely delete your personal data. In the case of disposal of hard copy papers (typically pertaining to UK criminal record checks) these are managed by way of secure confidential waste bins installed on-site and secure on-site shredding; the destruction of all confidential waste is carried out to BS15713:2009 security shredding standard by appropriately vetted members of staff.

Should you wish to request further information relating to the relevant retention period of your records please contact the relevant HR contact at the client who instructed Vero Screening to undertake the screening exercise.

Candidate portal screening form – Export-Import

You can download a copy of the data you input into your Candidate portal screening form in a machine-readable pdf format. Please note, your Candidate portal account will be scheduled for automatic purging 30 days after the screening exercise has been completed regardless of whether you have exported your data or not. However, the Client portal copy of your screening (including screening form, report and attachments) will be retained in accordance with the data controller’s chosen retention period. This is typically 12 months from screening completion.

Your rights as a data subject

UK and European Data Protection legislation gives you (as a data subject) a number of rights which include:

  • the right to information;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to request data portability; and
  • the right to object to processing.

Please note some restrictions may apply to the applications of the rights. For further details, please refer to the information provided on the website of The Information Commissioner https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

Please also note Vero Screening is a data processor acting on instructions to process your personal data from our client (the data controller). Vero Screening therefore advises you contact the HR representative at the client who intructed us to undertake your screening, should you wish to exercise any of your rights as a data subject. Vero Screening will assist our client to comply with fulfilling and evidencing such rights.

Right to Complain

You have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office – please refer to its website at www.ico.org.uk. You may contact the Information Commissioner’s Office as follows:

By email: Please complete the form at https://ico.org.uk/global/contact-us/email/

By phone: 0303 123 1113

By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Withdrawal of consent

Where you have been advised by our client that the lawful basis for processing your personal data for screening purposes is consent, you have the right to withdraw this consent at any time. You can do this by contacting the client who instructed us to undertake your screening.

As previously stated, Vero Screening is not involved in any decisions relating to your prospective or continuing contractual relationship with our client. Vero Screening can therefore take no responsibility for any action resulting from being unable to complete our client’s requested screening procedure, as a result of you withdrawing your consent.

Updates and further information

This Privacy Policy was updated on 2019-12-19. It may be updated to take into account changes at Vero Screening or for example to reflect changes to regulation or legislation.

Updates to this Privacy Policy will be posted on this page – please check back from time to time.


Vero Screening Ltd

19 December 2019

Introduction

Vero Screening Ltd (Vero Screening) is a limited company incorporated in England and Wales (Company number 05392085).

As part of any recruitment process, Vero Screening Ltd collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

This Privacy policy for Candidates gives you detailed information on when and why we collect your personal data, how we use it and how we keep it secure.

If you have questions regarding your personal data and how we use it, please contact our Data Protection Officer using the contact details below:

Data Protection Officer
Vero Screening Ltd
Princes House
Brighton
East Sussex
BN1 3XB
United Kingdom

Tel: +44 (0) 1273 840 800
Email: dpo@veroscreening.com

Overview

  • Lawful basis for processing;
  • The types of personal data we collect;
  • How we collect your personal data;
  • Why we collect your personal data and how we use it;
  • Change of purpose;
  • How we handle your personal data;
  • How we protect your personal data;
  • Your rights as a data subject;
  • Updates and further information.

Lawful basis for processing

We need to process data to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with legal obligations. For example, it is mandatory to check a successful applicant’s eligibility to work in the UK before employment starts.

Vero Screening Ltd has 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.

Vero Screening Ltd may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability.

The types of personal data we collect

Vero Screening Ltd collects a range of information about you. This includes:

  • Personal informaton such as your name, date of birth, 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;
  • 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.
  • If your successful in your application, information to enable us to undertake our pre-employment screening process.

We may obtain your personal data from the following sources (please note that this list is not exhaustive):

  • You (e.g. a Curriculum Vitae, application or registration form);
  • Other candidates or employees (e.g. through employee referral scheme);
  • Online jobsites;
  • The public domain;
  • Social Media;
  • At interview or attendance at assessment days;
  • Conversations on the telephone or video conferencing (which may be recorded);
  • Notes following a conversation or meeting;
  • Our websites and software applications

 

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).

Who has access to your 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.

We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with third parties as part of our background screening procedures. During this process you will be required to provide information into our candidate portal and will be provided with the privacy policy for candidates undergoing background screening.

How we protect your personal data

Vero Screening is committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected from unauthorised access and improper use.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify any applicable regulator of a breach where we are legally required to do so.

The personal data you provide may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen if we are asked by your (potential) employer to check your references for time spent working outside of the EEA and we engage a service provider based in the appropriate jurisdiction to perform the checks on our behalf. If Vero Screening transfers your personal data outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

Vero Screening recognises that some countries do not have the same standard of data protection afforded in most EU States, for this reason Vero Screening has a strict supplier management policy which includes the screening of all new suppliers, annual security questionnaires and reviews, and the use of formal processing agreements. Our processing agreements also include terms dictating that the suppliers:

  • Are only permitted to process your personal data for recruitment;
  • Can only retain your personal data for a maximum period of 90 days (unless they are restricted by law from doing this);
  • Must immediately notify Vero Screening of any suspected or actual data breach of your personal data;
  • Shall take all appropriate technical and security measures to safeguard your personal data;
  • Will only transfer your personal data in accordance with approved data transfer provisions.

For how long does Vero Screening Ltd keep data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

If your application for employment is unsuccessful, the organisation will hold your data on file for 3 (three) months after the end of the relevant recruitment process. If we wish to hold your data on file for longer, we will obtain your consent before doing so. If you agree to allow us to keep your personal data for longer, we will hold it for a further 6 (six) 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 Human Resources file (electronic and paper based) and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice on commencement of employment.

Candidate portal screening form – Export-Import

You can download a copy of the data you input into your Candidate portal screening form in a machine-readable pdf format. Please note, your Candidate portal account will be scheduled for automatic purging 30 days after the screening exercise has been completed regardless of whether you have exported your data or not. However, the Client portal copy of your screening (including screening form, report and attachments) will be retained in accordance with the data controller’s chosen retention period. This is typically 12 months from screening completion.

Change of purpose

We will only use your personal data for the purposes for which we collected it. Please note we may process your personal data without your knowledge or consent, where this is required or permitted by law.

How we handle your personal data

We may share your personal data with some of our suppliers who perform services on our behalf. We make sure anyone who provides a service for Vero Screening enters into an agreement with us and meets our standards for data security. They will not use your personal data for anything other than the clearly defined purpose relating to the service that they are providing. We may share your details with:

  • Suppliers who work on behalf of Vero Screening for the performance of any contract we enter into with them (eg to check your credentials and references in countries outside the UK).
  • Where required to do so, for example when requested by the police or a regulatory or government authority investigating illegal activities.

Your rights as a data subject

UK and European Data Protection legislation gives you (as a data subject) a number of rights which include:

 

  • the right to information;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to request data portability;
  • the right to object to processing.

Please note some restrictions may apply to the applications of the rights. For further details, please refer to the information provided on the website of The Information Commissioner https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ .

Right to Complain

You have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office – please refer to its website at www.ico.org.uk. You may contact the Information Commissioner’s Office as follows:

By email: Please complete the form at https://ico.org.uk/global/contact-us/email/

By phone: 0303 123 1113

By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

What if you do not provide personal data?

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

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer at dpo@veroscreening.com

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Updates and further information

This Privacy Policy was updated on 21 November 2018. It may be updated to take into account changes at Vero Screening or for example to reflect changes to regulation or legislation.

Updates to this Privacy Policy will be posted on this page – please check back from time to time.


Vero Screening Ltd
21 November 2018

Introduction

Vero Screening Ltd (Vero Screening) is a limited company incorporated in England and Wales (Company number 05392085). Vero Screening is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).

Vero Screening is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

If you have questions regarding your personal data and how we use it, please contact our Data Protection Officer using the contact details below:

Data Protection Officer
Vero Screening Ltd
Princes House
Brighton
East Sussex
BN1 3XB
United Kingdom

Tel: +44 (0) 1273 840 800
Email: dpo@veroscreening.com

Overview

  • Lawful basis for processing;
  • The types of personal data we collect;
  • How we collect your personal data;
  • Why we collect your personal data and how we use it;
  • Change of purpose;
  • How we handle your personal data;
  • How we protect your personal data;
  • Your rights as a data subject;
  • Updates and further information.

Lawful basis for processing

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 contract we have entered into with you

    Vero Screening ltd’s contractual responsibilities include those arising from the contract of employment. The data processed to meet contractual responsibilities includes, but is not limited to, data relating to: payroll; bank account; postal address; sick pay; leave; maternity pay; and pension and emergency contacts.

  • Where we need to comply with a statutory or legal obligation

    Our statutory responsibilities are those imposed on the company by legislation. The data processed to meet statutory responsibilities includes, but is not limited to, data relating to: tax; national insurance; statutory sick pay; statutory maternity pay; family leave; work permits; and equal opportunities monitoring.

  • 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:
    Vero Screening Ltd has a legitimate interest in processing personal data during employment. Processing data from employees allows us to manage the employment relationship. Our management responsibilities are those necessary for the organisational functioning of the company.The data processed to meet management responsibilities includes, but is not limited to, data relating to: recruitment and employment; training and development; absence; disciplinary matters; health and safety; security, e-mail address and telephone number; and criminal convictions.We may also need to process data from employees to respond to and defend against legal claims.
  • We may also use your personal information in the following situations, which are likely to be rare:
    – Where we need to protect your interests (or someone else’s interests)- Where it is needed in the public interest (or for official purposes)

How we use personal sensitive information

‘Special categories’ of particularly sensitive personal information requires high levels of protection. We need to have further justification for collecting, sotring and using this type of personal information.

Vero Screening Ltd may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, physical and mental health, disability, criminal allegations, proceedings or convictions, in the following circumstances:

  • In limited circumstances, with your explicit written consent.
  • Where we need to carry out our legal obligations in line with our data protection policy.
  • Where it is needed in public interest, such as for equal opportunities mointioring or in relation to our occupational pension scheme, and in line with our data protection policy.
  • Where it is needed to assess your working capacity on health grounds, subject to appropriate safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where is is needed to protect your interests (or someone elses interests) and you are not capable of giving your consent, or where you have already made the information public.

We will use your particulary sensitieve personal information in the following ways:

  • We will use information relating to leaves of absence, which may include sickness absence or family related leave, to comply with employment and other laws.
  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and management sickness abnsence and to administer benefits.
  • We will use information about your race, national or ethnic origin, religious, philosophical or moral believes, or your sexual life or secual orientation, to ensure meaningful equal opportunity monitoring and reporting.
  • We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent for us.

How we collect your personal data

  • when you access our candidate portal for screening purposes;
  • when you contact our HR department via telephone or email;
  • when we collect data through our HR and benefit systems;
  • when we collect data through the implementation of any HR Employee Relations Policies e.g. Disciplinary;
  • in the course of managing your employment, for example performance reviews, Payroll;
  • when you complete staff surveys;
  • when you apply for a vacancy internally or externally;
  • when we receive your Personal Data from third parties, for example security screening and recruitment agencies.

The types of personal data we collect

Information about you

 name, address, date of birth, marital status, nationality, race, gender, religion, and preferred language, details of any disabilities, work restrictions and/or required accommodations

Information to contact you at work or home

 name, address, telephone, and e-mail addresses.

Information about who to contact in a case of emergency (yours or ours)

 name, address, telephone, e-mail addresses and their relationship to you.

Information to identify you

 Photographs, passport and/or driving license details, proof of residence, electronic signatures.

Information about your suitability to work for us

 References, interview notes, work visas ID information such as passport details and driving licence information, records/results of preemployment checks, including criminal record checks, credit and fraud checks.

Information about your skills and experience

 CVs, resumes and/or application forms, references, records of skills and experience: qualifications, skills, training and other compliance requirements.

Information about your terms of employment with Vero Screening Ltd

 Letters of offer and acceptance of employment, your employment contract.

Information that we need to pay you

 Bank account details, national insurance or social security numbers (where applicable).

Information that we need to provide you with benefits and other entitlements

 Length of service information, health information, leave requests.

Information to allow you to access our buildings and systems

 Employee identification number (UIN), computer or facilities access and authentication information, identification codes, passwords, answers to security questions, photographs, video images.

Information relating to your performance at work

 Performance ratings, leadership ratings, targets, objectives, records of performance reviews, records and/or notes of 1 to 1s and other meetings, personal development plans, personal improvement plans, correspondence and reports.

Information relating to discipline, grievance and other employment related processes

 Interview/meeting notes or recordings, correspondence.

Information relating to your work travel and expenses

 Bank account details, passport, driving licence, vehicle registration

Why do we collect and use your information?

Recruitment

 To assess your suitability to workTo perform vacancy and applicant management activities

To conduct screening, assessments and interviews;

To maintain a library of correspondence;

To make offers and provide contracts of employment

To conduct pre-employment checks, including determining your legal right to work and carrying out criminal record and credit checks where applicable – for more information about Vero Screenings preemployment checks see our Personnel Screening procedure.

Human Resources (“HR”), finance and other business administration purposes

 Staffing, including resource planning, recruitment, termination, and succession planning;Budgetary and financial planning and administration; Organisational planning and development and workforce management

Compensation, payroll, and benefit planning and administration, including salary, tax calculations, reward and recognition payments, insurance and pensions

Workforce development, education, training and certification

Performance management;

Problem resolution, including carrying out internal reviews, grievances, investigations, audits;

Business travel and expense management

To conduct business reporting and analytics Administration of flexible work arrangements Administration of employee enrolment and participation in activities and programmes offered to eligible employees

Work-related injury and illness, including the management of employee Health & Safety, and disabilities

To communicate with you and to facilitate communication between you and other people Compliance and compliance reporting, including conflict of interest and gifts and hospitality reporting

Risk management, Project Management, Training and quality purposes.

Security purposes

 Physical access control authorizing, granting, administering, monitoring and terminating access to or use of our facilities, records, property and infrastructure including communications services such as business telephones and email/internet use
Prevention and detection of crime.

Information Technology (“IT”) administration purposes:

 IT Systems access control and use monitoring IT fault reporting, management and resolution systems administration, support, development, management and maintenance.

Legal purposes

 To comply with our legal obligations.

Who has access to your data

Your information may be shared internally for the purposes of managing the employment relationship. This includes members of the HR and recruitment team, training team, managers and IT staff if access to the data is necessary for the performance of their roles.

We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may also share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

All our third-party service providers 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.

For how long does Vero Screening Ltd keep data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Details of retention periods for different aspects of your personal information are available in our retention policy which is available from Human Resources. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

How we protect your personal data

Vero Screening is committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected from unauthorised access and improper use.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For further details please email dpo@veroscreening.com. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify any applicable regulator of a breach where we are legally required to do so.

The personal data you provide may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen if we are checking your references for time spent working outside of the EEA and we engage a service provider based in the appropriate jurisdiction to perform the checks on our behalf. If Vero Screening transfers your personal data outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

Vero Screening recognises that some countries do not have the same standard of data protection afforded in most EU States, for this reason Vero Screening has a strict supplier management policy which includes the screening of all new suppliers, annual security questionnaires and reviews, and the use of formal processing agreements. Our processing agreements also include terms dictating that the suppliers:

  • are only permitted to process your personal data for recruitment;
  • can only retain your personal data for a maximum period of 90 days (unless they are restricted by law from doing this);
  • must immediately notify Vero Screening of any suspected or actual data breach of your personal data;
  • shall take all appropriate technical and security measures to safeguard your personal data;
  • will only transfer your personal data in accordance with approved data transfer provisions.

We may also transfer your data to the USA. The USA has weaker data protection laws than that of the EEA and therefore we will ensure that only organisations who are a part of the EU-US Privacy Shield initiative will handle your personal data. More details on this certification can be found at www.privacyshield.gov/welcome.

Change of purpose

We will only use your personal data for the purposes for which we collected it. Please note we may process your personal data without your knowledge or consent, where this is required or permitted by law.

 

How we handle your personal data

We may share your personal data with some of our suppliers who perform services on our behalf. We make sure anyone who provides a service for Vero Screening enters into an agreement with us and meets our standards for data security. They will not use your personal data for anything other than the clearly defined purpose relating to the service that they are providing. We may share your details with:

  • Suppliers who work on behalf of Vero Screening for the performance of any contract we enter into with them (eg supply of benefits).
  • Where required to do so, for example when requested by the police or a regulatory or government authority investigating illegal activities.

Your rights as a data subject

UK and European Data Protection legislation gives you (as a data subject) a number of rights which include:

  • the right to information;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to request data portability;
  • the right to object to processing.

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 our Data Protection Officer at dpo@veroscreening.com

Please note some restrictions may apply to the applications of the rights. For further details, please refer to the information provided on the website of The Information Commissioner https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ .

Right to Complain

You have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office – please refer to its website at www.ico.org.uk. You may contact the Information Commissioner’s Office as follows:

By email: Please complete the form at https://ico.org.uk/global/contact-us/email/

By phone: 0303 123 1113

By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Vero Screening ltd during employment. However, if you do not provide required information, we may not be able to manage some or all aspects of the employment relationship.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer at dpo@veroscreening.com

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Updates and further information

This Privacy Policy was updated on 21 November 2018. It may be updated to take into account changes at Vero Screening or for example to reflect changes to regulation or legislation.

Updates to this Privacy Policy will be posted on this page – please check back from time to time.


Vero Screening Ltd
21 November 2018