Customer Experience Manager

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London City Airport Privacy Notice

The following explains how we London City Airport (LCY) intend to use the information you provide in your application, along with your rights, our reasons for requesting it and who will have access to it.

As defined by the General Data Protection Regulation (GDPR) London City Airport is the Data Controller and ultimately responsible for ensuring the data you provide is kept secure, processed correctly and that you understand your legal rights in relation to the data you provide.

The recruitment software we use via this website is supplied by IRIS Software Group Limited and they are defined as a Data Processor under the GDPR. They will only process your data in accordance with our instructions.

IRIS can be contacted at: 4th Floor Heathrow Approach, 470 London Road, Slough, England, SL3 8QY

For Data Protection enquiries, please contact the Help Desk at support@networxrecruitment.com

LCY’s data protection responsibilities

“Personal data” is any information that relates to an identifiable natural person. Examples of your personal data include your name, address, contact details, and CV.

The term “process” means any activity relating to personal data, including, by way of example, collection, storage, use, consultation and transmission.

LCY is the "controller" of your personal data for the purposes of your application. This is a legal term – it means that we make decisions about how and why we process your personal data and, because of this, we are responsible for making sure it is used in accordance with data protection laws.

What types of personal data do we process and where do we get it from?

We process many different types of personal data about you for lots of reasons (which are set out in the table below).

If any of the personal information you have given to us changes, such as your contact details, please inform us without delay by calling the telephone number provided as part of the application information.

We cannot administer our employment or other relationship with you without your personal data. Where it is not mandatory to provide your personal data, we will make this clear, for instance, it is not mandatory for you to provide us with information as to your ethnicity or sexual orientation, but if you provide us with this information, we will use it to allow us to identify if there are any groups of individuals that are under-represented in the groups of applicant for vacancies at LCY.

This information may either be provided by:

• you, either on your application form, your CV or during any interviews;
• by other parties, such as former employers, Government Departments and/or agencies, such as Department for Works and Pensions, Her Majesty’s Revenue and Customs and the Disclosure and Barring Service; or
• created by us (such as comments and feedback).

What do we do with your personal data, and why?

We process your personal data for particular purposes in connection with your application, and, if your application is successful, to allow us to undertake employee checks, including checking references, as well as to comply with legal obligations imposed on us before confirming any job offer. 

We are required by law to always have a so-called “lawful basis” (i.e. a reason or justification) for processing your personal data. There are a number of different lawful bases for processing (and for some processing activities, we consider that more than one legal basis may be relevant – depending on the circumstances) including:    

• necessary for us to comply with a legal obligation;
• necessary for the purposes of the legitimate interests pursued by LCY and that we consider that this overrides your interests or fundamental rights which require protection of personal data;
• necessary for the purposes of substantial public interests; and
• necessary for us to take steps, at your request, to potentially enter into an employment contract with you, or to perform it.

If you choose not to provide the relevant personal data to us, we may not be able to enter into or continue our contract of employment or engagement with you, or provide any additional benefit or service to you that you have applied for, and to which we require that relevant personal data.

Who do we share your personal data with, and why?

From time to time we may ask third parties to carry out certain business functions for us, such as the administration of our payroll and our IT support. These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties, only where necessary, so that they can perform those functions. Before we disclose your personal data to other people, we will make sure that they have appropriate security standards in place to make sure your personal data is protected and we will enter into a written contract imposing appropriate security standards on them. Examples of these third party service providers include service providers and/or sub-contractors, include our outsourced payroll, HR and marketing service providers, and our IT systems software and maintenance, back up, and server hosting providers.

In certain circumstances, we will also disclose your personal data to third parties who will receive it as controllers of your personal data in their own right for the purposes set out above, where the relevant disclosure is:

• if we buy or sell our business (or part of it) in connection with a share or asset sale, we may disclose or transfer your personal data to the prospective seller or buyer and their advisors; and
• if we need to disclose your personal data in order to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, customers or others.

We have set out below a list of the categories of recipients with whom we may share your personal data, where it is necessary to do so:

• Government bodies, including HMRC, DWP;
• Organisations providing goods and/or services on our behalf, including third party contractors. These may include organisations providing back-up storage services and other IT services;
• Our Auditors;
• Medical practitioners, including occupational health advisors;
• The Disclosure and Barring Service for Criminal Records Checks;
• Any contractors providing services required in relation to your application, including our legal advisors;
• Regulatory bodies, for example the CAA;
• Your former employer(s) and/or referees;
• Our legal advisors;
• Consultants and other professional advisors; and/or
• Any other third parties, where authorised or directed by you to do so.

At all times we will comply with our obligations under applicable Data Protection Laws.

Retention

If your application is unsuccessful, your personal data will normally be held for a period of 6 months from the date of the decision not to offer you the applied job, unless you have asked us to retain your details to allow us to notify you of any similar vacancies in the future.

If successful, any personal data processed as part of your employment records will normally be held for a period of 7 years from the end of your employment with us, except where we are:

• legally required to retain the information for longer;
• legally required to delete the information within a specified period of time; or
• where the personal data is required in relation to any legal or other type of dispute, either with you or with a third party.

Any personal data contained in any work related correspondence may be retained for longer, dependant on the relevant retention period for that work or matter.

If you require any further information relating the retention of your personal data, please contact us.

[Automated decision making

LCY uses automated decision making systems to exclude applications where it does not meet the key job specification criteria.]

Your rights

You have the right  to request the following, in respect of the processing of any of your personal data:

• access to your personal data;
• have any incorrect personal data corrected or erased;
• the restriction of the processing of your personal data whilst any request to have incorrect personal data corrected or erased is being considered;
• to object to any processing of your personal data undertaken on either public interest or legitimate interest grounds;
• to object to being subject to any decision based solely on automated processing;
• a review to any decision made based solely on automated processing, to be undertaken by a human, and provide additional evidence or submissions to support any review;
• a copy, provided in a structured, commonly used and machine readable format, of any personal data that you have provided us, where the information is processed on the basis of your consent or in the course of a contract between you and us.

Where we process your personal data solely on the basis of your consent, you are entitled to withdraw your consent at any point. If you chose to do this, this means that we will be unable to further process your personal data for that purpose, but any processing undertaken prior to the withdrawal of your consent would still be deemed lawful.

However, we may not be able to comply with your requests, where the information falling within the scope of your request is exempt, due to the circumstances and/or purposes to which we are processing this information. If this is the case, we will respond to your request explaining the reasons why we are unable to comply with your request.

Within your candidate account, you can also use the Download Data feature to generate an XML file of the current data we hold on you that you have provided and/or have access to within the account.

Where you exercise your right to object or withdraw your consent we may process your personal data without your knowledge or consent where we are permitted or required by law or regulatory requirements to do so. In such a case, we will not process more personal data than is required under the circumstances.

If you are not satisfied by our actions, you can seek recourse through our internal complaints procedure. If you remain dissatisfied, you have the right to refer the matter to the Information Commissioner (www.ico.org.uk) or seek recourse through the courts.

What Personal Data do we collect or process, in the course of processing your application?

We collect information that is specifically provided by you as part of an application process. We will collect the following (but not limited to):

• Name, address, email, telephone number;
• Information provided by you in your CV including career history, education, other skills and any other relevant professional memberships or qualifications;
• Answers to application questions;
• application reference number;
• Details of the position you have applied for;
• Whether you are currently employed by or on behalf of LCY, either as an employee or contractor;
• Whether you are at risk of redundancy or are on a fixed term contract;
• How you heard about the vacancy;
• Whether you require any additional adjustments due to any medical condition;
• Your availability for interviews;
• Agreed interview times and dates;
• Copies of any correspondence or other documents created by LCY when considering your application, including interview notes and feedback of the interviewers;
• Claims for expenses;
• Equalities opportunities monitoring information, including information as to your sexual orientation, gender reassignment, health/disability, ethnic origin and/or religion/philosophical beliefs - this information is purely for statistical analysis and monitoring purposes;
• Equalities information, including information as to your marital status and gender;
• Information relating to your skills and experience, if you are unsuccessful in your application, to inform you if any other relevant vacancies arise;
• Any other information you wish to provide in support of your application.

If your application is successful, and you accept our job offer, we will process the following personal data:

• Name;
• Address;
• Contact telephone numbers;
• E-mail address;
• Date of Birth;
• Former/ recent residential addresses;
• Proofs of ID;
• UK Passport;
• evidence of entitlement to work in the UK;
• References;
• Equalities opportunities monitoring information, including information as to your sexual orientation, gender reassignment, health/disability, ethnic origin and/or religion/philosophical beliefs - this information is purely for statistical analysis and monitoring purposes;
• Equalities information, including information as to your marital status and gender.

Why do we collect this information?

• To allow us to contact you in relation to your application.
• To allow us to contact you where we are required by law to do so.
• To allow us to reference your application, and ensure that any correspondence or communications received are filed correctly.
• To allow us to identify whether your education, skills and experience (both in and outside the work place) meets the requirements for the advertised vacancy.
• To allow us to match your experience and work history against the requirements of the position.
• to allow us to determine whether, if you are successful, you are required to undergo the pre-employment and vetting process.
• To allow us to identify how effective our job advertisement process is.
• LCY is an equal opportunity employer and to allow us to meet any obligation to make reasonable adjustments in compliance with the Equality Act 2010. Where you have indicated you require any reasonable adjustments, we will contact you to discuss what support or adjustments we can reasonably offer you to assist you in the application process.
• To allow us to arrange a mutually convenient time and date for any interview.
• To allow us to consider and record the reasons whether your application is successful or unsuccessful.
• To process any claims for travelling expenses;
• We are required to retain records of any payments made by us for accounting and auditing purposes.
• To allow analytics teams to prepare anonymised statistical reports for equal opportunities and equality monitoring.
• Whether you have consented to LCY retaining your CV so that we can notify you of any other vacancies arise that suit your skills and experience.
• We are required to validate your identity;
• We are required to undertake a check, under the Immigration, Asylum and Nationality Act 2006 to check and retain evidence of the check of your entitlement to work in the United Kingdom.
• To allow us, if your application is successful, to undertake an enhanced criminal records check (which includes spent convictions) for individuals who have accepted a job that is falls under CAA regulation;
• To validate the employment history provided by you;
• To allow analytics teams to prepare anonymised statistical reports for equal opportunities and equality monitoring.

Where can you find out more?

If you have any queries or concerns about your personal data your first point of contact would be our Data Protection e-mail  DataProtectionqueries@londoncityairport.com

If you want more information about any of the subjects covered in this privacy notice or if you would like to discuss any issues or concerns with us, you can also e-mail us at DataProtectionqueries@londoncityairport.com