Recruitment Privacy Policy

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data for all activities related to job applications and the recruitment process.

We keep this Privacy Notice under review and will reflect any updates or changes to practice within this Privacy Notice. This Notice was last reviewed on 17 April 2024.

1 Important information and who we are

1.1 Purpose of this Privacy Policy

(a) For Kocho to operate our recruitment process, we need to process personal information about candidates and job applicants. The organisation is committed to being transparent about how it collects and uses data in line with data protection obligations. The purpose of this Privacy Notice is to inform you how we will use and protect personal information provided by candidates.

(b) Except as set out in this Notice, or as required by law, your personal data will not be provided to any third party without your prior written consent.

1.2 Controller

(a) Kocho is a controller of your personal data under the Data Protection Act 2018 (“DPA”) and the UK General Data Protection Regulation (“GDPR”) for all activities related to job applications and the recruitment process.

(b) We have appointed a Group Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the following details:

Group Data Protection Officer
Kocho
Waverley House
7-12 Noel St
Soho, London
W1F 8GQ
[email protected]

(c) You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

1.3 Changes to the privacy notice and your duty to inform us of changes

(a) It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.4 Contact details for recruitment

(a) Our email address for all recruitment purposes is [email protected] and our phone number is 0800 044 5009.

2 The data we collect about you

2.1 Your personal data will be held by Kocho. This will include information within your application and any additional information about you that you provide, or that is provided by others as part of the recruitment process. This includes the following:

• Your application form and any attached correspondence; the content of any emails, letters and telephone calls (which may be recorded) and any conversations.
• Your name, address and contact details including telephone number and email address.
• Details of your education history, employment history (including absence information), your qualifications, skills and experience.
• Information about your current levels of remuneration, including benefit entitlements, notice periods.
• Any information we receive from referees or from other organisations such as agencies.
• Any information related to credit checking and criminal activity.
• Information for your entitlement to work in UK.
• If you have a disability or there are other factors that Kocho needs to take into account in the recruitment process, including the need to make reasonable adjustments to the process to meet your requirements.

2.2 Special Categories and Criminal information

(a) Some personal information is defined as “special categories” data (for example information related to ethnic origin, political opinions, religious beliefs, physical/mental health). Data may also be required in relation to, criminal proceedings and offences. We may request this type of information as part of the recruitment process for the purposes of Equal Opportunities Monitoring or for carrying out Disclosure and Barring Service (DBS) checks.

(b) If we do request this sensitive information, where appropriate, we will:

• Ask for your explicit consent to the processing of this information.
• Ensure such information is treated confidentially.

2.3 References

(a) Successful candidates will be asked to provide references and other background check information, such as proof of right to work, credit and other financial history checks, and sometimes criminal records checks.

(b) We will seek references only once an offer of employment has been made and we will obtain your consent before we contact your referee. It is your responsibility to ensure the referee is aware you have provided us with their details and is happy for you to do so and that they are happy to be contacted by us.

3 Submitting your personal data

3.1 Kocho collects information in a variety of ways, for example through application forms, CVs, obtained from your passport or any other identity documents, or information collected through interviews or other forms of assessment.

3.2 By submitting your personal data and application for employment, you:

• Declare you have read, understood and freely accept the statements provided in this Privacy Notice.
• Declare the information provided is complete and accurate to the best of your knowledge.
• Understand that deliberate omissions and incorrect information may lead to your application being rejected.
• Allow Kocho to process the information contained in your application and any other information you may provide separately as part of the recruitment process in support of your application.
• And for successful candidates, authorise Kocho to make any reference checks, credit and criminal checks that are considered as necessary for your application.

4 How we handle your personal data

4.1 While processing your application we may contact you by post, email, telephone or text message using the contact details you provided. During the recruitment process we may research comments and opinions via publicly available social media platforms such as LinkedIn, Twitter and Facebook. Your personal data you provide as part of the recruitment process will only be held and processed for the purpose of the recruitment/ selection process and in connection with subsequent employment/ placement.

4.2 Kocho has a legitimate interest in processing personal data during the recruitment process and keeping records for the process. Processing data from the recruitment process allows us to manage the recruitment process, assess the suitability of the candidate for employment and to decide whether to make an offer of employment.

4.3 In the event of your application being successful (resulting in an offer of employment and your acceptance of that offer), the personal information collected by Kocho during the recruitment process will be held in recruitment and HR systems, and emails or other IT systems for the duration of your employment, subject to the Kocho Privacy Notice for Employees.

4.4 In the event your application was unsuccessful, your personal information will be held on our system for a period of up to 6 months. The purpose of the retention of this personal data is that it might be accessed or re-used in future recruitment processes or in relation to subsequent applications for employment made by you and to respond to statutory reporting requests. At the end of the period as stated above, or once you withdraw consent, your data will be deleted and destroyed.

5 Sharing your personal data

5.1 Where your application for employment with us is via a recruitment agency, we will share your details with them.

5.2 If you are successful in your application and we make a search via a credit reference agency in assessing your application, we will keep a record of the search whether or not the results are successful or not. Our search results are used for purposes related to money laundering and debt. You have the right to request this information from the credit reference agency.

6 Who has access to your data?

6.1 Your information will be shared internally for the purpose of the recruitment exercise. This includes members of the People and recruitment teams, interviewers and managers involved in the recruitment process.

7 How do we protect your data?

7.1 We take the security of your data seriously. We have internal policies and controls in place to ensure your data is not lost, accidentally destroyed, misused or disclosed and is not accessed by other employees where the roles do not form part of their working activities.

8 Your rights

8.1 You have a number of rights with regard to your personal data. You have the right to:

• Request a copy of the personal data that we hold about you.
• Correct or delete your personal data.
• Restrict, suspend, or pause the processing of your personal data, if, for example, it is wrong and needs to be changed.
• Object to the processing of your personal data, as well as in certain circumstances the right to data portability.

8.2 If you have provided consent for the processing of your data you have the right to withdraw that consent at any time. This will not affect the lawfulness of the processing before your consent was withdrawn.

9 What if you do not provide personal data?

9.1 You are under no statutory, or contractual obligation to provide personal data to Kocho during the recruitment process.

9.2 However, if you do not provide this information, it might affect our ability to process your application properly, or even at all.