Data Protection Policy for Job Applicants

This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the application process. Please read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

Who collects the information?

Friend MTS Limited, (incorporated in England and Wales, CRN 03513618, registered office Eleven Brindley place, 2 Brunswick Square, Birmingham, B1 2LP) and any companies in its group (FMTS) is a data controller and gathers and collects and uses certain information about you. This information may also used by our affiliated entities and group companies, such as Friend MTS (US) Inc. (our group companies). In this notice, references to ‘we’ or ‘us’ mean FMTS and our group companies.]

About the information we collect and hold

We may collect the following information up to and including the shortlisting stage of the recruitment process:

• Your name and contact details (i.e. address, home and mobile phone numbers, email address);

• Details of your qualifications, experience, employment history (including job titles, salary and working hours) and interests;

• Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs; and

• Details of your referees.

We may collect the following information after the shortlisting stage, and before making a final decision to recruit:

• Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers ☐;

• Information regarding your academic and professional qualifications ☐;

• Information regarding any criminal record you may have (whether in a criminal records certificate (CRC) or enhanced criminal records certificate (ECRC) or otherwise;

• Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information ☐;

• Information relating to your health, including vaccination status;

• A copy of your driving licence; and

• Credit history and status.

You are required (in order to enter into your contract of employment or by law) to provide the categories of information marked ‘☐’ above to us to enable us to verify your suitability for the position and right to work.

How we collect the information

We may collect this information from you, your referees (details of whom you will have provided), your education provider, the relevant professional body, the Disclosure and Barring Service (DBS), the Home Office, other Governmental bodies and credit reference agencies.

Why we collect the information and how we use it

We will typically collect and use and otherwise process this information for the purposes of determining whether to make you an offer of employment and the terms of that offer and entering into a contract of employment with you and any ancillary purposes.

We do so on the following legal bases:

• to take steps before entering a contract or to perform a contract;

• to comply with a legal or regulatory obligation;

• for our legitimate interests or those of a relevant third party (such as a benefits provider), but only if these are not overridden by your interests, rights or freedoms, including;

– carrying out our obligations or exercising rights under employment law;

– for reasons of substantial public interest (i.e. equality of opportunity or treatment, promoting or retaining racial and ethnic diversity at senior level, preventing or detecting unlawful acts);

– to establish, exercise and/or defend any legal claims that may be brought by or against us in connection with your recruitment; and

• where you give us your voluntary consent for a specified purpose.

We seek to ensure that our information collection and processing is proportionate.

How we may share the information

We may also need to share some of the above categories of personal information with other parties, such as HR consultants and our professional advisers. The recipients will be bound by confidentiality obligations. We may also be required to share some information to comply with the law.

Sensitive personal information and criminal records information

Further details on how we handle sensitive information, also known as special category personal information and information relating to criminal convictions and offences are set out in our policy for processing such information, available from the HR department.

How long do we keep your information?

We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. This will depend on whether your application is successful such that you become employed by us, the nature of the information concerned and the purposes for which it is processed.

We will keep recruitment information (including interview notes) for no longer than the limitation periods for potential claims such as discrimination (as extended to take account of early conciliation), after which they will be destroyed.

If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment.

Your right to object to us processing your information

Where our processing of your information is based solely on our legitimate interests (or those of a third party), you have the right to object to that processing if you give us specific reasons why you are objecting, which are based on your particular situation. If you object, we can no longer process your information unless we can demonstrate legitimate grounds for the processing, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

Your rights to correct and access your information and to ask for it to be erased

Please contact our General Counsel, who can be contacted at if you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice or wish to exercise your right to object. You also have the right to ask for some but not all of the information we hold and process to be erased in certain circumstances.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

How to complain

We hope that our General Counsel can resolve any query or concern you raise about our use of your information, but you have the right to complain to the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

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Friend MTS Limited
Eleven Brindleyplace, 2 Brunswick Square
Birmingham
B1 2LP
United Kingdom

UK: +44 121 633 5750
US: +1 267 382 4280