Candidate Privacy Notice
The Travel Chapter Ltd is committed to respecting your privacy and will protect your Personal Information
The Travel Chapter Ltd is aware of its obligations under the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with UK GDPR, the types of data that we collect and hold on you as a candidate. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
This statement is applicable to candidates. It is not intended to, neither will it, form part of any contract of employment or contract of services. We reserve the right to make changes to this statement at any time, if you are affected by substantial changes, we will make an alternative statement available to you.
Data controller details:
The Travel Chapter Limited under UK Privacy Law is classified as a Data Controller, meaning that it determines the processes to be used when using your personal data.
Our contact details are as follows:
We are The Travel Chapter Group. All references to “we” “our” “us” or “company” within this privacy notice are deemed to refer to Travel Chapter House, Gammaton Road, Bideford, EX39 4DF our ultimate parent company Country Topco Limited (company no 11724257), its subsidiaries, affiliates and/or any of our brands.
Our registered office is Travel Chapter House, Gammaton Road, Bideford, Devon. EX39 4DF, United Kingdom.
Information Commissioner’s Office (the ICO) Reference number: Z4968059.
Data protection principles
In relation to your personal data, we will:
- process it fairly, lawfully and in a clear, transparent way
- collect your data only for reasons that we find proper for during the recruitment process, in ways that have been explained to you
- only use it in the way that we have told you about
- ensure it is correct and up to date
- keep your data for only as long as we need it
- process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed
Types of data we process
We hold many types of data about you, including:
- your personal details including your name, address, date of birth, email address, phone numbers
- whether or not you have a disability
- information included on your CV including references, education history and employment history
- documentation relating to your right to work in the UK
How we collect your data
We collect data about you in a variety of ways including the information you would normally include in a CV or a job application cover letter, or notes made by our recruiting officers during a recruitment interview. Further information will be collected directly from you when you complete forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references. Personal data is kept in personnel files or within the Company’s People Team and IT systems.
Why we process your data
The law on data protection allows us to process your data for certain reasons only:
- You have given clear consent for us to process your personal data for a specific purpose.
- in order to perform the employment contract that we are party to
- in order for us to carry out our legitimate interests
- in order to carry out legally required duties
- to protect your interests and;
- where something is done in the public interest.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first four reasons set out above to process your data.
We need to collect your data to ensure we are complying with legal requirements such as:
- carrying out checks in relation to your right to work in the United Kingdom and;
- making reasonable adjustments for disabled employees.
We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:
- making decisions about who to offer employment to
- making decisions about salary and other benefits
- checking you are legally entitled to work in the UK
- assessing qualifications for a particular job or task
- dealing with legal claims made against us
- in order to fulfil equal opportunity monitoring or reporting obligations
If you are unsuccessful in obtaining employment, we will seek your consent to retaining your data in case other suitable job vacancies arise in the Company for which we think you may wish to apply. You are free to withhold your consent to this and there will be no consequences for withholding consent. We will hold the data for 2 years, then we will delete all data.
Special categories of data
Special categories of data may be collected during the recruitment process, but they will be anonymised by our information system and will not be used as part of the recruitment process. It will be used in anonymised form by our people team to gather statistics on the types of individuals applying for roles within our Company. The anonymised data set will include the following:
- Religious or philosophical beliefs
- Sex life or sexual orientation
We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
- you have given explicit consent to the processing
- we must process the data in order to carry out our legal obligations
- you have already made the data public.
We will use your special category data:
- for the purposes of equal opportunities monitoring and reporting
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not able to process, or continue with (as appropriate), your application.
Sharing your data
Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties with regard to recruitment. This includes, for example, the People Team, those in the department where the vacancy is who responsible for screening your application and interviewing you, the IT department where you require access to our systems to undertake any assessments requiring IT equipment.
In some cases, we will collect data about you from third parties, such as employment agencies.
Your data will be shared with third parties if you are successful in your job application. In these circumstances, we will share your data in order to obtain references as part of the recruitment process.
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. We have a Data Protection Policy and an IT Security Policy that all employees of the Travel Chapter are required to follow when processing personal data, and there are a number of supporting procedures to ensure each Team or Department process your data in the same way.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with the UK GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for, and this will depend on whether or not you are successful in obtaining employment with us.
If your application is not successful, we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for 12 months once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for 2 years once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
Automated decision making
We will make some decisions about you based on automated decision making (where a decision is taken about you using an electronic system without human involvement). We believe that you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. You will be asked to answer some pre-screening questions during the application process, these will then be used to consider if you meet the requirements of the job role and if you proceed to the interview stage.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
- the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
- the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
- the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
- the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
- the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- the right to portability. You may transfer the data that we hold on you for your own purposes
- the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
- the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact:
Data Protection Team
Email Address: [email protected]
Address: The Travel Chapter Ltd, Travel Chapter House, Gammaton Road, Bideford, EX39 4DF
Making a complaint
If you would like to make a complaint about how we have processed your data, please contact our Data Protection Team using the information in the section above. If after we have investigated your concerns you are still not happy then and you think your data protection rights have been breached in any way by us, you are able to make a complaint to the UK data protection regulator the Information Commissioner’s Office (the ICO (the UK Supervisory Authority)).
‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data we gather may include: individuals' phone number, email address, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.
Special categories of personal data
Special categories of personal data include information about an individual's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition, criminal offences, or related proceedings, and genetic and biometric information.
‘Data controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law.
‘Data processor’ means a natural or legal person, public authority, agency or other body, which processes personal data on behalf of the controller.
‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
This is the national body responsible for data protection. The supervisory authority for our organisation is the Information Commissioner’s Office.