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Welcome to Penna, part of the Adecco Group. Penna are working as a trusted supplier on behalf of Homes England. We look forward to working with you to help you to further develop your career. As you’d expect, to properly perform our services, we will collect and use information about you for the purpose of your application working for Homes England.
As part of your application, Penna will be collecting and sharing your information with Homes England and relevant parties for recruitment purposes only. This will be in relation to working for Homes England only.
Penna is committed to protecting and respecting your privacy. This Candidate Privacy Information Statement describes your privacy rights in relation to the information about you that we process, as well as the steps we take to protect your privacy. We know it’s long, but please read this Statement carefully. There is an index below so you can go straight to the relevant information if you prefer.
- Some terms to be clear about
- What personal information does the company collect and use?
- Why do we use personal information about you?
- What does the law say about this?
- Do you have to give us the personal information we ask for?
- Do we process information about you without any human intervention at all?
- How long do you keep my personal information for?
- Do we transfer your data to third parties?
- Do we transfer your data outside the European Union?
- What are your rights?
- What about data security when using Adecco Systems?
- How could you contact us?
- How do we handle changes to this Statement?
Some terms to be clear about
First, we need to be clear about how we use some words in this statement.
It may seem obvious, but in this Statement, you will be referred to as ‘the Candidate’ or ‘You’.
When we talk about 'us' or the 'Company' we mean Penna for candidates registering in the UK. The registered office for Penna is Millennium Bridge House, 2 Lambeth Hill, London EC4V 4BG. The Company is part of the Adecco Group, the largest HR services provider in the world. Through its various companies and business lines the Adecco Group provides several HR (Human Resources) activities like staffing, secondment, payroll services, recruitment & selection, testing solutions, career transition, talent development, training & education, outplacement and international mobility ('our Activities').
To carry out our Activities the Company uses several IT systems. In some cases, the Company provides a Self-Service Portal (‘Portal’) for its candidates/personnel.
Finally, this is a statement about information about people – like you and your family. It includes facts about you, but also opinions about you and that you hold (“I’m a football fan” for example). It’s not about information about the Company (although sometimes the two overlap). This type of information is sometimes called ‘Personal information’, ‘Personally Identifiable Information’ or ‘PII’. We use the term ‘Personal Information’ in this Statement.
What personal information does the company collect and use?
Personal information that the company usually collects includes, but is not limited to:
- Your name, date and place of birth, contact details and qualifications (education, training courses and internships), documents evidencing your identity and right to work and any other information you listed on your resume or CV;
- If you log on to the Portal using your LinkedIn or any other social media account: your profile data;
- If you contact us, in some cases we will keep a record of that correspondence;
- Feedback about you from our staff and third parties; where you give feedback on others, we usually keep that too and that is also personal information about you (it’s your opinion after all);
- We may also collect information on your visits to our website/Portal including (but not limited to) your IP address, browser, timestamp, location, country traffic data, location data, weblogs and other communication data and the resources that you access. This information will make your visit to our website/Portal easier in the future.
- We may also collect information for marketing purposes and analysis, including information on how your respond to email, sms, phone and other marketing campaigns;
- Photos and videos of your attendance at training or similar sessions (you will be given a chance at the session to ask not to be videoed or photographed);
- Details of any disabilities and any accommodations we may need to make for you in the workplace; and
- In some cases, we will also collect sensitive personal information where we are permitted to do so by law (so in some countries we will ask you about your background for equal opportunities monitoring).
Why do we use personal information about you?
The company collects and processes personal information:
- To provide you with the services you expect us to such as progressing your application for Homes England, helping you with training, or facilitating the process of applying for jobs/assignments
- to further develop, test and improve our website/Portal, or other existing or new systems/processes to better serve you; this mainly takes place in the context of new IT systems and processes, so that information about you may be used in the testing of those new IT systems and processes where dummy data cannot fully replicate the operation of that new IT system;
- to perform studies and statistical and analytical research, for example to compare the effectiveness of our placement of candidates between different business sectors and geographies and seek to identify factors that might influence any differences we identify;
- to transfer data to third parties (see below);
- where necessary, to comply with any legal obligation; and
- we may also process your information to:
a. promote the security and protection of people, premises, systems and assets;
b. monitor compliance with internal policies and procedures;
c. administer communications and other systems used by the Adecco Group (including internal contact databases);
d. investigate or respond to incidents and complaints;
e. in the case of photos or videos of training sessions, to report internally that the training sessions have taken place and their content (for example in internal updates) and also to market similar sessions internally and externally to third parties;
f. comply with obligations and rights and cooperate with investigations carried out by the police, government or regulators; and
g. participate in any potential or actual purchase or sale, or joint venture, of all or part of a business or company, that any member of the Adecco Group wishes to participate in.
What does the law say about this?
We are required by law to have a ground set out in the law to process the information we hold about you.
When you are working with or through Penna our processing of personal information for all these purposes is based on processing grounds like the performance of a contract to which the data subject is a party (purposes 1 and 6-7), processing necessary to comply with legal or regulatory obligations (purpose 6-7) and/or processing necessary in the legitimate interests of Penna in exercising its and its staff fundamental rights to run a business in a way which does not unduly affect your interests or fundamental rights and freedoms (purposes 1-5 and 7). When processing is necessary for the legitimate interests of Penna, we ensure that processing is conducted in such a manner that our legitimate interests outweigh any individual’s interest. We shall only process your personal information other than on these grounds with your consent (a further processing ground).
Do you have to give us the personal information we ask for?
You are not obliged to provide your personal information to us, but it is more or less impossible for us to work with you and provide our services if you do not.
Do we process information about you without any human intervention at all?
Yes, we do at times. The Company may use automated systems/processes and automated decision-making (like profiling) to provide you, and our clients, with the services you request from us. For example, when our clients are looking for candidates for jobs, we may conduct a search of our lists of candidates using automated criteria which takes into account your availability, skillset, pay rate and in some circumstances previous feedback we have received from clients to compile a shortlist which ranks which candidates are most likely to fulfil the client’s requirement. This means that sometimes your position in the rank may be higher than others, depending on how these factors match the clients’ needs.
How long do you keep my personal information for?
Penna will retain your information during the length of our relationship with Homes England. At the end of this, at the written discretion of Homes England; we will then delete or return any of your personal information (and any copies of it) that Penna has obtained, generated or gathered to Homes England.
If you are successful through us, the Company may also need to keep your personal information for a longer period in order to comply with its on-going legal and contractual obligations. Generally, we retain your personal data concerning taxes, contracts of employment and where relevant, financial information for 7 years, and other personal information for 2 years. After this period, all of your information will be removed from our systems, or sooner upon instruction from Homes England.
Do we transfer your data to third parties?
As mentioned above, we usually disclose your data to third parties. This is done to complete the purposes set out above. We do this in the following circumstances:
- To our suppliers. We may, for example, engage a supplier to carry out administrative and operational work in support of our relationship with you. The supplier(s) will be subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy, and will only have access to the data they need to perform their functions; the relevant suppliers are typically IT suppliers (who host or support our IT systems, including information about you), premises management companies (who look after physical security at our buildings, and therefore may need to know about you to allow access to our buildings) and back office finance and accounting management providers (who might need to handle details of candidates in order to process accounts payable and receivable). We may also engage suppliers who provide IT technology services and solutions, which might include video interview and skills assessment tools.
- To members of the Adecco group of companies in other countries. These may be located in- or outside the European Union; different members of the group fulfil different functions and as result your information may be shared with them for different reasons:
- information is shared with members of the Adecco group that provide IT functions for the Adecco companies world-wide; those IT functions are located among others in France.
- To our clients/prospective employers: we will share your data with our client Homes England who are offering jobs/assignments you may be interested in, or who are interested in your profile. They owe contractual and other confidentiality obligations in relation to your data to us, and to you;
- We will share your data with government, police, regulators or law enforcement agencies if, at our sole discretion, we consider that we are legally obliged or authorised to do so or it would be prudent to do so; and
- As part of due diligence relating to (or implementation of) a merger, acquisition or other business transaction we may need to disclose your data to the prospective seller or buyer and their advisers.
Do we transfer your data outside the European Union?
We shall only transfer your data outside of the UK, and within the European Union only, to countries where;
- The Adecco Group has put in place appropriate safeguards to seek to preserve the privacy of your information (for which we usually use one of the forms of data transfer contracts approved by the European Commission, copies of which are available here: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.
- The Adecco Group complies with its obligations under the Data Protection Legislation by providing an adequate level of protection to any Personal Data that is transferred
What are your rights?
- Right to access and obtain a copy of your personal information
You are entitled to request confirmation whether we process any of your personal information. Where this is the case, you may have access to some of your personal information (via the Portal) and to certain information about how it is processed. In some cases, you can ask us to provide you with an electronic copy of your information.
- Right to correct your personal information
If you can demonstrate that personal information we hold about you is not correct, you can request that this information is updated or otherwise corrected. We would encourage you to access the self-service Portal where possible and update your personal information directly.
- Right to be forgotten/have data deleted
In certain circumstances you have the right to request that we restrict the processing of your personal data and/or that your personal data is deleted. You may make such a request at any time and Penna will evaluate if your request should be granted, however this right is subject to any legal rights or obligations we may have to retain data. For situations where in accordance with the law, we determine that your request to have your personal information deleted must be granted, Penna will do so without undue delay. Please bear in mind, once your data is deleted – that the Company might not be of service to you anymore once this data about you has been deleted. If you want to re-register with the company again, you will need to re-enter your data.
- Right to object
As far as the company’s processing of your data is based on the company’s legitimate interest (and no other processing ground) or relates to direct marketing, you are entitled to object to the Company processing your data by reference to your particular situation.
If you want to exercise any of your rights, please log into the self-service Portal (if available) or contact the UK&I privacy lead directly at firstname.lastname@example.org.
When you email us to exercise your rights, the Company may ask you to identify yourself before actioning your request.
Finally, you have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.
What about data security when using Penna Systems?
You are responsible for keeping your login details to the Portal safe, in particular the password that we have given you or that you have chosen. These login credentials are for your own use. You are not permitted to share your credentials or other account details with any other person(s).
How could you contact us?
If you have any questions or concerns regarding our Statement, would like further information about how we protect your information (for example when we transfer it outside Europe) and/or when you want to contact the company’s Group Data Protection Officer (DPO) and your local Privacy Lead, please email us at email@example.com.
How do we handle changes to this Statement?
The terms of this Statement may change from time to time. We shall publish any material changes to this Statement through appropriate notices either on this portal or contacting you using other communication channels.
The Penna Team