Corporate Human Resources

Important Information: For prospective and current employees of the Council

Introduction

Your personal data is data which by itself or combined with other data available to Conwy County Borough Council, can be used to identify you.  Conwy County Borough Council is the data controller.  This Privacy Statement sets out to you how Conwy CBC will use your personal data, submitted in relation to job applications and subsequent employment with the Council.  You can contact our Data Protection Officer (DPO) at:

Whether or not you become a Council employee, we will use your personal data for the reasons set out below, and if you become an employee, we will use it in relation to managing your employment.

We’ll collect most of this directly during the application and recruitment process, and further information post employment.  The sources of collecting personal data indirectly are mentioned in this statement.

The personal data we may use may include:

• Full name and personal details including contact information (eg home address, email address, home and mobile telephone numbers)
• Date of birth and/or age (eg for Disclosure and Barring Service checks and pension purposes)
• Financial details (eg current salary)
• Education and qualifications (eg to establish suitability for post)
• Banking details (for payment of salary)
• Sickness information (post employment)  
• Employment history

We take your privacy seriously and this privacy statement sets out how we will handle your personal data securely and in accordance with your rights.  See the attached (link to Corporate Privacy Statement) www.conwy.gov.uk/privacynotices

Providing your personal data

The Council will tell you if providing some personal data is optional, including asking for your consent to process.  In all other cases you must provide your personal data so the Council can process your application and fulfil its employment responsibilities.

Using your personal data (which could include both written data and your personal image) the legal basis and purposes

We will process your personal data

As necessary to perform our contract with you as an employer:

• To manage and perform that contract
• To update your records
• To use your contact details as necessary

As necessary  for the performance of a task carried out in the public interest:

• For good governance, safety, security of assets, accounting and managing your employment contract
•  For developing statistics for employment monitoring purposes

As necessary to comply with a legal obligation eg:

• When you exercise your rights under data protection law and make request
• For compliance with legal and regulatory requirements and related disclosures
• To verify your identity

With your consent e.g:

• When you request us to disclose your personal data to other organisations eg. Gwynedd Pensions if you wish to join the Local Government Pension scheme or otherwise agree to disclosures (eg to access Training or Employee Benefits Schemes)
• When we process any special categories about you for statistical purposes only (eg racial or ethnic origin, religion, data concerning health, sexual orientation.

You are free to change your mind and withdraw your consent at any time

The Council is required by law to protect the public funds it administers and so may use any information you have provided for the prevention, detection and investigation of fraud and irregularity, for the performance of a contract, or, task carried out in the public interest, or to comply with a legal obligation.   Part 6 of the Local Audit and Accountability Act 2014 and the Accounts and Audit (Wales) Regulations are the Legal basis. 

Sharing of your personal data

Subject to applicable data protection law, we may share your personal data :

• With Gwynedd Pension Scheme
• With Government bodies (eg HMRC who may in turn share it with other tax authorities and regulators)
• With the Police and Courts (to comply with legal requirements and the administration of justice)
• In an emergency or otherwise to protect your vital interests
• When we restructure or transfer a service or a merger or re-organisation with another organisation
• When a request is received from a future prospective employer for a reference
• Anyone else where we have your consent or as required by law

Identity verification and fraud prevention checks

The personal data we have collected from you at application will be used during the recruitment process to verify your identity.  If fraud is detected you could be refused employment in future.  We may also search and use our internal records for these purposes. 

Automated decision making and processing

Automated decision making involves processing my personal data without human intervention.  (On occasion this happens prior to completing an application eg to establish that they are an internal candidate when the post is only open to existing employees)

Criteria used to determine retention periods

The following criteria are used to determine data retention periods for your personal data:

• If you do not proceed to become an employee, your data will be retained for no longer than 7 months post application date.
• Retention for employees -  We will retain your personal data as long as necessary to process any employment requirements and deal with any queries or requests, during or post employment, in accordance with our retention schedule for human resource records.

Data anonymization and aggregation

Your personal data may be converted into statistical or aggregated data, which cannot be used to identify you, then used to produce statistical research and reports.  This aggregated data may be shared and used in all the ways described above.

Your rights under applicable Data Protection Law

Your rights are as follows (noting that these rights don’t apply in all circumstances and that data portability is only relevant from 25 May 2018)

• The right to be informed about our processing of your personal data.
• The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed.
• The right to object to processing of personal data.
• The right to restrict processing of your personal data.
• The right to have personal data erased (the “right to be forgotten”)
• The right to request access to your personal data and information about how we process it.
• The right to move, copy or transfer my personal data (“data portability”)

You have the right to complain to the Information Commissioner’s Office which has enforcement powers and can investigate compliance with data protection law: https://ico.org.uk/

For more details of the above you can contact our Data Protection Officer, Derek O’Connor,  at the above address or by email : Derek.Oconnor@conwy.gov.uk   

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