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Processing of (personal) data by the entity in charge of the online application process

ETF RECRUITMENT PRIVACY NOTICE

1 Introduction

1.1 This Privacy Notice provides individuals that engage with the Education and 
Training Foundation’s (the ETF, we, us, our) recruitment processes with information 
about how your personal data will be used, in compliance with the UK General Data 
Protection Regulations (UK GDPR) 2018 and the Data Protection Act (DPA) 2018. The 
ETF is a registered charity (registration no: 1153859) and a company limited by 
guarantee (company registration number (England and Wales): 08540597). When 
referring to the ETF, we also include our professional membership organisation, the 
Society for Education and Training (SET).
Protection Act (DPA) 2018.
1.2 The ETF processes personal data required for recruitment activities. 
1.2.1 Personal data refers to any information relating to a living individual who 
could be directly or indirectly identified through their information (examples 
include, but are not limited to: date of birth, address, phone number, job title, 
previous employment information, e-mail address. 
1.2.2 Personal data can be stored electronically or in paper records.
1.2.3 Processing relates to collecting, storing, sharing, altering, and deleting 
personal data. 
1.2.4 For further information about the ETF’s practices in relation to data 
processing, data protection, guidance on complying with the UK GDPR and key 
terminology, please contact our Data Protection Officer (DPO).
2 What information does the ETF collect?
2.1 The ETF is committed to being transparent about how we collect and use data to 
meet data protection obligations (see also your ‘Right to be informed in section 7). 
Throughout your engagements during recruitment at the ETF, we collect and hold a 
range of data about you that may be able to identify you directly or indirectly. We cannot 
administer recruitment processes without your personal data. 
2.2 Most data provided to us is obtained during our recruitment process via applications 
either directly or through recruitment agencies. 
2.3 The following list outlines the range of the personal data the ETF processes:
 Name and contact details 
• Terms and Conditions of any offer made to you if successful in your application 
including entitlement to benefits such as pensions or insurance cover and your 
bank account and national insurance number
• Details of your qualifications, skills, experience, and employment history, 
including start and end dates, with previous employers and with the ETF
• Information about your nationality and entitlement to work in the UK
• Information about medical or health conditions, including whether you have a 
disability for which the ETF needs to make reasonable adjustments for 
recruitment activities 
• Equality and Diversity monitoring information, including information about your 
race, sex, sexual orientation, gender reassignment, religion of belief, marital or 
civil partnership status, age, disability or pregnancy and maternity and socio-economic background.

2.4. We may, on occasion carry out Disclosure Barring Service (DBS) checks to ensure 
we safeguard the ETF's staff, stakeholders, and assets. This will only be where there 
are regulatory or contractual requirements and will be set out in the job advertisement. 
Please refer to the ETF Policy on Recruiting Ex-Offenders for further information (this 
can be accessed from the ETF website). 
3 Why does ETF process personal data? 
3.1 There is a need for the ETF to process data for recruitment purposes and also in the 
event where a candidate is successful in order to enter into an employment contract 
with individuals and then to meet all our obligations under that employment contract. In 
some instances, the ETF needs to process data to ensure we are complying with legal 
obligations. For instance, we are required to check to ensure individuals are permitted 
to work in the UK, to deduct tax, to disclose employee salary details to HMRC, comply 
with health and safety laws, to enable employees to take leave which they are entitled 
to, and to consult with employees or their representatives. This list is not exhaustive.
4 Who has access to the data?
4.1 Internal: Information will be shared with the HR team. Some information will be 
shared with the IT team and in some instances where necessary the recruiting manager
and members of the Senior Leadership Team. It may also be shared with Finance for 
management accounting purposes.
4.2 External: ETF may need to share your data with third parties, such as to obtain preemployment references from other employers and to obtain background checks. ETF 
may need to share data with external parties for the purpose of enforcing legal rights. 
These third parties include: 
• LinkedIn 
• Team Tailor 
• National Audit Office to supply visitor building passes during face to face 
interviews and to facilitate fire/health and safety records. 

5 How do we protect data at ETF?
5.1 The ETF takes the security of our employee’s data seriously. Where the ETF 
engage third parties to process personal data they do so under a duty of confidentiality. 
Details of how information is kept secure can be found in our Information Security 
Policy, which is available on request
5.2 Whilst we don’t actively transfer data outside of the EEA, third-party provider 
TeamTailor’s systems are based in the US, therefore data is stored in the US. As per 
their privacy notice (section 6. Security) TeamTailor have measures to protect Personal 
Data in accordance with GDPR regulations.

6 Data retention periods
6.1 Personal data information will be stored for as long as necessary to carry out the 
recruitment process and if a job offer is made to you and you accept then our Staff 
Privacy notice will apply which contains additional detail on retention.

7 Your rights
7.1 As a data subject, you have a number of rights. You have the: 
• Right to be informed. This policy addresses that right by detailing to you, as an 
ETF employee how your personal data is being used. 
• Right to access. Including a right to obtain a copy of your data by making a Data 
Subject Access Request (DSAR). Guidance for employees on how to make a 
DSAR can be found here. 
• Right to portability. If you do make a DSAR, we will provide you with your 
information in a way that is accessible and machine-readable. We will also, on 
request as part of this right, transfer your data to another organisation as long as 
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the transfer is technically feasible, the data is held electronically, and you 
personally provided us with the information. 
• Right to rectification. To request that ETF corrects, or updates incomplete data 
held about you. 
• Right to erasure in certain circumstances. You may request that the 
organisation deletes or stops processing your data (also known as the ‘Right to 
be forgotten’.) Certain data deletion restrictions may apply, however, for example 
if the ETF is legally obliged to keep hold of your data such as to comply with 
financial or other regulations; when keeping your data is necessary for the 
purposes of occupational health or when it is for the assessment of the working 
capacity of the employee; If you would like any of the above rights exercised, where applicable to do so, please 
contact the Recruitment team (recruitment@etfoundation.co.uk) .
8 Contacting us
8.1 The ETF is located at the premises of The National Audit Office, 157-197 
Buckingham Palace Road London SW1W 9SP. We can be contacted via phone; 020 
3740 8280 and by email at recruitment@etfoundation.co.uk.

Processing of (personal) data by the operator of the recruitment website

General information

This recruitment website is operated by Personio SE & Co. KG, which offers a human resource and candidate management software solution (https://www.personio.com/legal-notice/). Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. The sole controller of this data within the meaning of article 24 of the GDPR is the enterprise carrying out this online application process. Personio’s role is limited to operating the software and this recruitment website and, in this context, being a processor under article 28 of the GDPR. In this case, the processing by Personio is based on an agreement for the processing of orders between the controller and Personio. In addition, Personio SE & Co. KG processes further data, some of which may be personal data, to provide its services, in particular for operating this recruitment website. We will refer to this in more detail below.

The controller

The controller under data protection law is:
Personio SE & Co. KG
Seidlstraße 3
80335 München
Tel.: +49 (89) 1250 1004
Entry in the commercial register
Commercial register entry number: HRA 115934
Registration Court: Amtsgericht München
Data Protection Officer contact: privacy@personio.com

Access logs (“server logs”)

Each access to this recruitment website automatically causes general protocol data, so-called server logs, to be collected. As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. Without this data, it would, in some cases, be technically impossible to deliver or display the contents of the software. In addition, processing this data is absolutely necessary under security aspects, in particular for access, input, transfer, and storage control. Furthermore, this anonymous information can be used for statistical purposes and for optimizing services and technology. In addition, the log files can be checked and analyzed retrospectively when unlawful use of the software is suspected. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. Generally, data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp of the access to the software is collected. The scope of this log process does not exceed the common log scope of any other site on the web. These access logs are stored for a period of up to 7 days. There is no right to object to this.

Error logs

So-called error logs are generated for the purpose of identifying and fixing bugs. This is absolutely necessary to ensure we can react as quickly as possible to possible problems with displaying and implementing content (legitimate interest). As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. When an error message occurs, general data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp upon occurrence of the respective error message and/or specification is collected. These error logs are stored for a period of up to 7 days. There is no right to object to this.

Use of cookies

So-called cookies are used on parts of this recruitment website. They are small text files which are stored on the device with which you access this recruitment website. As a general rule, cookies serve the purpose of ensuring secure access to a website (“absolutely necessary”), implementing certain functionalities such as standard-language settings (“functional”), improving the user experience or the performance of the website (“performance”), or placing targeted advertisements (“marketing”). On this recruitment website, we generally use only cookies that are absolutely necessary, functional or performance-related, in particular for implementing certain default settings such as language, for identifying the job advertising channel, or for analyzing the performance of a job advert via which a user accessed this recruitment website. The use of cookies is absolutely necessary for providing our services and thus for the performance of the contract (article 6 (1) b) of the GDPR). Period of storage: up to 1 month or until the end of the browser session Right to object: You can determine via your browser settings whether you allow or object to the use of cookies. Please note that deactivating cookies may result in limited or completely blocked functionalities of this recruitment website.

Rights of data subjects

If Personio SE & Co. KG as the controller processes personal data, you as the data subject have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and the purpose of the processing, in particular the right of access (article 15 of the GDPR) and the rights to rectification (article 16 of the GDPR), erasure (article 17 of the GDPR), restriction of processing (article 18 of the GDPR), and data portability (article 20 of the GDPR), as well as the right to object (article 21 of the GDPR). If the personal data is processed with your consent, you have the right to withdraw this consent under article 7 III of the GDPR. To assert your rights as a data subject in relation to the data processed for the purpose of operating this recruitment website, please refer to Personio SE & Co. KG’s Data Protection Officer (see item B).

Concluding provisions

Personio reserves the right to adjust this data privacy statement at any point in time to ensure that it is in line with the current legal requirements at all times, or in order to accommodate changes in the services offered, for example when new services are introduced. In this case, the new data privacy statement applies to any later visit of this recruitment website or any later job application.