Vero Hero

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Introduction

Vero Screening Ltd (Vero Screening) is a limited company incorporated in England and Wales (Company number 05392085). We provide pre-employment and in-employment 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 your (potential) employer (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 website4. From our client – your (potential) employer – who requires your employment 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

Your (potential) employer is responsible for determining the lawful basis for your employment screening. The collection of your personal data is done in accordance with their instructions. Separately, Vero will ask for your signed consent. This consent is required to facilitate the employment 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 consent does not alter the lawful basis for processing determined by your (potential) employer. Furthermore, should you withdraw or withhold this consent it will have no bearing on your (potential) employer’s lawful basis for employment screening.

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

Should you have any questions in relation to the consequences of withholding your personal data and / or withholding or withdrawing your consent to the screening process you should make contact with your HR Representative at your (potential) employer.

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 your (potential) employer, 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 employment screening process your (potential) employer 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 that you contact the relevant HR contact at your prospective/existing employer.

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 your (potential) employer, and therefore only provides the information in an objective manner. Your (potential) employer (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:

  • Your (potential) employer;
  • 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 employment screening purposes as instructed by your (potential) employer). 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 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 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 your (potential) employer, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In relation to the employment screening report and information gathered during the course of the screening, your (potential) employer 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 your prospective/existing employer.

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 your (potential) employer (the data controller). Vero Screening therefore advises that you contact the HR representative at your (potential) employer should you wish to exercise any of your rights as a data subject. Vero Screening will assist your (potential) employer 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 your (potential) employer that the lawful basis for processing your personal data for employment screening purposes is consent, you have the right to withdraw this consent at any time. You can do this by contacting the HR representative at your (potential) employer.

As previously stated, Vero Screening is not involved in any decisions relating to your prospective or continuing employment status. Vero Screening can therefore take no responsibility for any action resulting from being unable to complete your (potential) employer’s requested screening procedure, as a result of you withdrawing your consent.

Updates and further information

This Privacy Policy was updated on 2018-05-08. 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


08 May 2018