Privacy Policy for Job Applicants

What is the purpose of this document?

Leicester Theatre Trust Ltd (the Company) is committed to protecting the privacy and security of your
personal information.

This privacy notice describes how we collect and use personal information about you. It provides you
with certain information that must be provided under the UK General Data Protection Regulation
(UK GDPR).

You are being sent a copy of this privacy notice because you are applying for work with us (whether
as an employee, worker, contractor, freelancer or creative).

The Company is a “data controller”. This means that we are responsible for deciding how we hold and
use personal information about you. We are required under data protection legislation to notify you of
the information contained in this privacy notice.

The contact details for the Company are: Leicester Theatre Trust Ltd, Curve Theatre, Rutland Street,
Leicester, LE1 1SB.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you
must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that
is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymous
data).

There are “special categories” of more sensitive personal data which require a higher level of
protection.

In connection to your application to work with us, we will collect, store, and use the following
categories of personal information about you:

• The information you or a recruitment agent have provided to us in your curriculum vitae and any
covering letter.
• The information you have provided on any application form, including name, title, address,
telephone number, and personal email address, date of birth, gender, employment history,
qualifications, and referee details.
• Any information you provide to us during any interview or assessment/tests.

We may also collect, store and use the following “special categories” of more sensitive personal
information:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your health, including any medical condition, health and sickness records.
• Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about job applicants and candidates through the application and
recruitment process, either directly from candidates or sometimes from an employment
agency/recruitment provider or background check provider. We may sometimes collect additional
information from third parties including former employers, credit reference agencies or other
background check agencies and your named referees. We may also (where relevant and required by
law) obtain information relating to criminal convictions through the Disclosure and Barring Service.

How we will use information about you

We will only use your personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the role/work;
• Carry out background and reference checks, where applicable;
• Communicate with you about the recruitment process;
• Keep records related to our recruitment processes;
• Comply with legal or regulatory requirements.
• Making a decision about your recruitment or appointment.
• Determining the terms on which you work for us.
• Checking you are legally entitled to work in the UK.

It is in our legitimate interests to decide whether to appoint you to a role since it would be beneficial to
our business to do so. Having received your CV and/or covering letter and/or any applicable
application form we will then process that information to decide whether you meet the basic
requirements to be shortlisted for the role. If you do, we will decide whether your application is strong
enough to invite you for an interview. If we decide to call you for an interview, we will use the
information you provide to us at the interview to decide whether to offer you the role. We may also
make use of assessments/tests during any selection process, and use information from that to help us
make recruitment decisions. If we decide to offer you the role, we will take up references and/or may
carry out a criminal record check (if relevant and legally required) before confirming your appointment
and will process your personal information to decide whether to enter into a contract with you.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your
application, we may not be able to process your application successfully. This may mean that we are
unable to take your application further.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection.
This information includes the following information: race or ethnic origin, political opinions, religious or
philosophical beliefs, trade union membership, genetic/biometric data, health, sex life or sexual
orientation.

We will use special categories of personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide
appropriate adjustments during the recruitment process, for example whether we need to make
adjustments for the interview or any assessment.
• We will use information about your race or ethnic origin, religious or philosophical beliefs, or your
sex life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Information about criminal convictions

We may have to collect information about criminal convictions, if relevant and if legally required taking
into the account the nature of the role you have applied for. If this is relevant to you we will inform you
in advance and explain why this information is necessary.

We will ensure that we have in place appropriate safeguards when processing this type of
information, and will seek to do so in accordance with our data protection policy.

We may only use information relating to criminal convictions where the law allows us to do so.

Due to the fact that we occasionally work with children and vulnerable adults, if relevant to your role,
we are required to undertake checks of job applicants or employees, workers, consultants and
freelancers to check their suitability for such work. Such checks include checks regarding spent and
unspent criminal convictions. We are permitted to obtain this information under Part II, Schedule 1 of
the Rehabilitation of Offenders Act (Exceptions) Order 1975 (as amended).

All checks for these purposes are carried out using the Disclosure and Barring Service (DBS). We use
the information received from a DBS check to determine your suitability for the role. Any job offer or
agreement for you to undertake work with us may (dependant on the role) be conditional on you
agreeing to submit to a DBS check and to our receiving the outcome of such checks to determine
your suitability for employment or engagement with us. Such checks will be renewed periodically.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on
automated decision-making.

Data sharing

We may have to share your data with third parties for the purposes of processing your application. For
recruitment purposes, those third parties are likely to include Net-Worx (2001) Ltd who are our online
recruitment application provider and the DBS.

The recruitment software we use via this website is supplied by Net-Worx (2001) Ltd (trading as
networx) and they are defined as a Data Processor under the UK GDPR. They will only process your
data in accordance with our instructions. networx can be contacted at: The Engine House,
Wharfebank Business Centre, Ilkley Rd, Otley LS21 3JP. The Data Protection Officer for networx is
Rob Baker and can be contacted at [email protected]

We require third parties to respect the security of your data and to treat it in accordance with the law.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the
possible sale or restructuring of the business. We may also need to share your personal information
with a regulator or to otherwise comply with the law.

Data security

We have put in place measures to protect the security of your information. Details of these measures
are available upon request.

Third parties will only process your personal information on our instructions and where they have
agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal information to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal information on our
instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you
and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

If we do not recruit you but have obtained personal information from you for the purposes of a
recruitment process, we will retain your personal information for a period of 6 months after we have
communicated our decision. We retain this information for that period so that we can show, in the
event of a legal claim, that we have not discriminated against candidates on prohibited grounds and
that we have conducted the recruitment exercise in a fair and transparent way. After this, unless you
ask us to hold your personal data for longer we will securely destroy your personal information in
accordance with our data protection policy and any policies on retention of personal information.

If we do recruit you we will retain the personal information relating to your application (CV, application
form, interview assessment/notes, tests etc) and hold this in your personnel file for the period of your
employment/engagement. Such information will be removed from your file after the termination of
your employment/engagement in accordance with our data protection policy and any policies on
retention of personal data. If you become an employee, worker, or consultant with the Company, we
will issue you with a separate Privacy Notice at that point which will explain what personal information
we will retain regarding you whilst you remain employed/engaged by us.

Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal information we hold about you and to
check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have
any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove
personal information where there is no good reason for us continuing to process it. You also have
the right to ask us to delete or remove your personal information where you have exercised your
right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes you want
to object to processing on this ground. You also have the right to object where we are processing
your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to
suspend the processing of personal information about you, for example if you want us to establish
its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the
processing of your personal data, or request that we transfer a copy of your personal information to
another party, please contact HR Director in writing at the address indicated above.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or
excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure
your right to access the information (or to exercise any of your other rights). This is another
appropriate security measure to ensure that personal information is not disclosed to any person who
has no right to receive it.

Right to withdraw consent

In the limited circumstances where we have relied on your consent for the collection, processing and
transfer of your personal information for a specific purpose (which will be rare), you have the right to
withdraw your consent for that specific processing at any time. To withdraw your consent, please
contact HR Manager at the address indicated above. Once we have received notification that you
have withdrawn your consent, we will no longer process your information for the purpose or purposes
you originally agreed to, unless we have another legitimate basis for doing so in law.

Data Protection Manager

We have appointed Claire Ward, Director of Audiences to oversee compliance with this privacy
notice. If you have any questions about this privacy notice or how we handle your personal
information, please contact Claire Ward using the contact details above. You have the right to make a
complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for
data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new
privacy notice when we make any substantial updates. We may also notify you in other ways from
time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact either Claire Ward or
Shilpa Mistry

Last revision: March 2023