Recruitment Privacy Statement
ClarusONE Sourcing Services LLP (hereinafter referred to as “we”, “us” and “our”) is jointly owned by its two member companies who are McKesson Strategic Services Limited and WMGS Europe Limited.
This Recruitment Privacy Statement describes how we handle and protect the personal information of any individual applying to work with us (whether as an employee, worker or contractor) (“you”) that is shared with us in connection with our recruitment process. We are a “data controller” for the purpose of data protection laws, meaning we are responsible for deciding how we collect and process your personal information.
We respect your privacy and are committed to protecting your personal information. We encourage you to read this Recruitment Privacy Statement in full to understand our privacy practices before submitting or providing any personal information to us. This Recruitment Privacy Statement does not form part of any contract of employment or services that may be offered to job applicants.
Your Consent
By making available your personal information, you confirm and consent that you have reviewed this Recruitment Privacy Statement and agree that we may process your personal information in accordance with this Recruitment Privacy Statement, other applicable laws, and contractual obligations.
How your personal information is collected
We will collect personal information directly from you (as the job candidate), from third parties (i.e., recruitment agencies, former employers, your named referees, law enforcement agencies and background check providers) or through your interaction with our websites and other public sources (e.g., LinkedIn profile).
Data Protection Principles
We will comply with the data protection principles of applicable data protection laws. This means that all personal information in our possession will be:
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Used lawfully, fairly and in a transparent way;
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Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
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Relevant to the purposes we have told you about and limited only to those purposes;
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Accurate and kept up to date;
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Kept only as long as necessary for the purposes we have told you about; and
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Kept securely.
The kind of information we will hold about you
In connection with your application for work with us, we will collect, store and use the following categories of personal information about you:
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Name and contact information, such as telephone number, title, address and email address;
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Previous work experience or work history such as job titles, working hours and training records;
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Education and other skills;
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Current or previous salary, annual leave, pension and benefits information, notice period in current employment or other work assignment (where applicable), and location of current employment or other work assignment (where applicable);
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Professional and other work-related licenses, permits, and certifications;
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Awards and professional memberships;
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Audio and video recordings of interviews;
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Employment and background checks;
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Employment references (including current and previous employment and/or academic or personal references);
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Copies of right to work documentation and other identification documentation; and
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Any other personal information provided by you as part of the recruitment process.
We endeavour to maintain the accuracy and completeness of your personal information that we store and to ensure that all of your personal information is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal information, or if you become aware that we have inaccurate personal information relating to you.
Sensitive Personal Information
During the recruiting process we may process sensitive personal information, which includes:
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Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
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Information about your health, including any medical condition, health and sickness records.
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Information about criminal convictions and offences.
We will use your sensitive personal information in the following ways:
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We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
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We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
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We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process.
Collection and Use
We will limit the collection and use of personal information to that which is relevant and reasonably necessary to accomplish legitimate business purposes for which it is collected and used. We will collect and use your personal information in accordance with this Recruitment Privacy Statement, applicable laws, and contractual obligations.
We shall process your personal information for the following purposes:
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Assessing your skills, qualifications, and suitability for the position applied for;
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Checking you are legally entitled to work in the UK or any other jurisdiction in which you may be offered work;
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Processing your job application;
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Keeping records related to our recruitment processes;
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Analysing the recruitment process and its outcome;
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Conducting criminal history, background, and employment checks;
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Communicating with you regarding the recruitment process, your inquiries, any requests that you may have, and/or send important notices to you;
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Complying with legal or regulatory requirements and any contractual obligations; and
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Conducting surveys concerning your experience.
When you submit an application for a position, we will add your personal information to our candidate database and will use it for the purposes of considering your suitability for the role to decide whether you meet the basic requirements to be shortlisted for an interview. If we decide to invite you for an interview, we will use the information you provide to us to decide whether to offer you the role. If we elect to make you an offer, the personal information you submit may be incorporated into our and/or our affiliated companies’ and/or members’ human resources information system and used to manage the new-hire process and we shall take up references and carry out a criminal record check before confirming your appointment.
If you become an employee, any personal information that you submit may become part of your employee file.
Lawful Basis for Processing
We will process your personal information on one or more of the following legal grounds:
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it is in our legitimate interests to decide whether to appoint you since it would be beneficial to our business to appoint someone to the vacant role; In order to decide whether to enter into a contract with you;
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to comply with a legal obligation (for example, to provide appropriate adjustments related to a disability during our recruitment process).
If we need to use and/or disclose your personal information for secondary purposes (for example, benchmarking as part of our legitimate interests in conducting and managing our business or where necessary to comply with a legal obligation), the data set will be aggregated, de-identified, or rendered anonymous prior to such use or disclosure.
Choice
If you are offered an online digital interaction screening or recording interview process, you may always decline and opt to schedule an in-person or over-the-phone discussion with our recruitment team.
Where we intend to use personal information in a manner not directly related to the purposes listed in this Recruitment Privacy Statement, you will be provided an opportunity to opt-out of the specific use of your personal information. Notwithstanding that you may have opted-out of the disclosure of your personal information, we reserve the right to disclose your personal information:
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To the extent and for the period necessary to avoid prejudicing our legitimate interests in making promotions, appointments, or other similar employment decisions;
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To service providers acting as our agent, that is, performing tasks on behalf of us and under our instructions;
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Where otherwise permitted under applicable law.
Automated Decision Making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Sharing your Personal Information
We will limit disclosure of personal information, internally and externally, to those with a business "need to know" and in accordance with this Recruitment Privacy Statement, applicable law, and contractual obligations. We will take steps to help ensure appropriate protections are in place before we share or disclose personal information. All our third-party service providers and affiliated companies are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.
We may provide your personal information to other third parties:
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To provide services to support the recruitment process as well as to facilitate post-offer processes and certain steps involved in initiating the employment relationship. These third parties are authorised to use personal information about you only as necessary to provide these services;
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As required by applicable law;
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To protect our rights or property, protect your health and safety, or the health and safety of others;
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To investigate fraud, illegal activity, or respond to a government request;
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To respond to an emergency; and
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As required for a merger, acquisition or sale of all or a portion of assets. In such a case, the successor company will acquire the same rights and obligations that we have related to your personal information.
Your personal information will be also reviewed by companies affiliated to us or our members who have a business need to access such personal information and may include human resources personnel, technical services personnel, and managers or their designees.
International Data Transfer
We may transfer the personal data we collect from you to parties based outside the UK. When we do, such transfers will only be to countries which are deemed to provide an adequate level of protection and/or we will rely upon the execution of approved ‘Standard Contractual Clauses’ which prescribe the level of protection to be given to that data to govern those transfers, which is in line with UK data protection law.
If you are not based in the UK, any personal data collected from you will also be transferred to the UK, which is where ClarusONE is located.
We will be happy to provide you with the relevant, detailed information on request.
Security
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 staff, 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 and their legal obligations under data protection laws.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Retention of Personal Information
We retain personal information relating to candidates applying for jobs in accordance with our policies and practices, applicable law and contractual obligations.
If there is no activity in relation to the personal information, we may remove it from our database or that of our affiliated companies and/or members, subject to its data retention obligations, policies, and any applicable legal or regulatory obligations or for the period of time permitted by local laws, for the purpose of considering whether your skills are suitable for other opportunities. Note that we may delete personal information about you at any time (including your CV/résumé), without any reason. Therefore, please retain your own copy of the personal information provided to us.
Although you may change your personal information, we may retain in backup or inactive files the uncorrected or outdated personal information. Such information may be retained for several reasons, including backups for disaster recovery planning, dispute resolution purposes, troubleshooting, and enforcement of agreements.
Rights of Access, Correction, Erasure and Restriction
You are entitled, by law to the following rights:
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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;
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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;
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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;
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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;
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Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information, for example if you want us to establish the data's accuracy;
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Request the transfer of your personal information to you or to a third party; and
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Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to process that personal information unless we have another legitimate basis for doing so. An email is sufficient.
If you wish to exercise any of the rights set out above, please contact us using our contact details below.
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 is clearly unfounded, repetitive or excessive.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to help speed up our response.
Are You Required to Provide Personal Information
If you fail to provide personal information when requested that is necessary for us to consider your application, we will not be able to take your application further.
Further Questions, Feedback or Complaints
If you have any questions about this Recruitment Privacy Statement or you would like to raise a complaint or comment please contact us by emailing us at Data_Governance@clarusonesourcing.com or by writing to us at: Attn: Data Protection Coordinator, ClarusONE Sourcing Services LLP, Russell Square House, 10-12 Russell Square, London, WC1B 5EH United Kingdom.
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 (www.ico.org.uk). We would, however, appreciate the opportunity to address your concerns before you approach the ICO so please contact us in the first instance.
Amendments
We keep our Recruitment Privacy Statement under regular review and reserve the right to amend this Recruitment Privacy Statement at any time. Any changes will be published on our website and shall take effect immediately. Please therefore regularly check this Recruitment Privacy Statement to make sure you are aware of the latest version.
Last updated January 2022