Privacy Policy

LAST MILE INFRASTRUCTURE GROUP LIMITED

JOB APPLICANT PRIVACY NOTICE

Definitions

"Us", "We" or "Last Mile Group" refers to Last Mile Infrastructure Group Limited and all our direct and indirect subsidiary companies.

"You" refers to anyone applying for a vacancy with us.

 

Introduction

This notice provides an overview of the practices of Last Mile Group with respect to the collection, holding, use and disclosure (collectively, processing), for recruitment-related purposes, of personal information about prospective employees.

We are a data controller which means we are responsible for deciding how we hold and use your personal data. This privacy notice explains everything you need to know about how we manage your personal data in relation to our recruitment processes.

When we refer to personal data, we mean information about you from which you can be identified. We take your privacy seriously and we want you to feel comfortable with the information you give us. It is important that your personal data is accurate and up to date. Please inform us if your personal data changes during the recruitment process. 

Special categories of personal data means information about (including, but not limited to) your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; health; sexual orientation; genetic data; or biometric data for the purpose of uniquely identifying you. 

Data marked * in the table in the 'Processing your personal data' section below falls within these ‘special categories’ or might disclose special categories of personal data. We must have additional legal grounds for processing special categories of personal data, and these grounds are set out in the table.

We will collect, hold, and process personal data relating to you if you apply for a position with us. We will use the information you give us to progress your application for the role you apply for, and to inform you of any other suitable roles, if you consent to this. If we decide to offer you employment, personal data gathered as part of your application will be used in connection with that offer and your employment with us, and we will provide you with access to a copy of our Group Privacy Notice for employees.

 

What personal data do we gather and where do we get it from?

In our recruitment process, personal data comes from you either directly or via a recruitment agency on your behalf, or generated by us. However, it may also come from the following sources:

  • Former employers or other referees, whom you have given us permission to contact, may provide us with the following personal data: role(s) held, dates of employment, details of skills and capabilities and any other information used to assess your suitability for the position offered to you

  • Medical professionals may provide us with the following personal data: health information and sickness records, including information relating to any disability that you may have, the effects of that disability, and adjustments that may need to be made as a result of that disability

  • Our staff may provide us with the following personal information: information relevant to our recruitment of you, if they referred you for recruitment; information relating to your employment with us, including information on your performance and conduct

  • Google and social networking accounts (such as LinkedIn): during your recruitment we may have sourced personal information relating to previous employment, skills and capabilities, and other information to assess your suitability for the position offered to you; during your employment we may collect information from these sources if it is relevant to your employment with us

The table in the 'Processing your personal data' section below lists your personal data that we will process about you.

Diversity and equality information

During the recruitment process you will be asked to provide answers to questions that help us monitor diversity within our organisation. If you opt to provide diversity data (you have the choice whether or not to provide this), this will only be used for monitoring and reporting purposes only. This personal data will not be visible to hiring managers during the selection process, and your personal data in reports will be aggregated so as not to identify you personally.  

 

Who sees my personal data?

Only those who have a legitimate need to access your personal data will be able to do so. Access to your personal data is usually restricted to members of the Last Mile HR team and line managers involved in the recruitment process for the role you’ve applied for, other than in exceptional circumstances in line with the purposes set out in this Notice, e.g. if required by law.

 

During the recruitment process, your personal data is stored securely on our ATS (Applicant Tracking System). Access to this data is limited to Last Mile Group employees who are directly involved with the hiring process (such as the Talent Acquisition Advisor, HR and hiring managers). 

If you start work with us following the recruitment process, your personal data will be transferred to our HR system, and you will be provided with access to our Last Mile Infrastructure Group Privacy Notice. 

 

When we share your personal data with third parties

Otherwise, we may share your personal data with the following third parties if this is required by law; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person:

  • Other entities in the Last Mile Group of companies for the purposes of internal administrative purposes and uses that are consistent with this notice.

  • Service providers who perform services on our behalf or for your benefit, such as for processing employment applications and performing human resources administration including Tribepad which provides our ATS, and DocuSign which we use for your employment contract and new starter paperwork. 

  • Health professionals and occupational health providers involved in your care, for the purposes of establishing whether you can undergo an assessment which forms part of the application process; and/or considering reasonable adjustments to the recruitment process for disabled applicants; establishing whether you will be able to carry out a function that is intrinsic to the particular work; establishing whether you are eligible for our guaranteed interview scheme for disabled applicants; and / or assessing your fitness to work if you have accepted an offer of work from us that is subject to health checks.

  • Our professional advisors including (but not limited to) our legal and accountancy service providers.

  • Our regulators and auditors including HMRC, the Home Office (for sponsored employees) Ofgem, Ofwat, the HSE, the Environment Agency, the Drinking Water Inspectorate and Lloyds Register – to fulfil our legal obligations and to assist them in fulfilling their regulatory functions. 

  • Other third parties as necessary to comply with the law.

 

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

 

Processing your personal data

We may process your personal data during and after the recruitment process. This may include collecting your personal data, recording it, storing it, using it, amending it, destroying it and, in some circumstances, disclosing it.

Generally, we do not rely on consent as a legal basis for processing your personal information except where applicable law requires this. You have the right to withdraw consent at any time by contacting us.

We set out below the purposes for which we process specific personal data relating to you and our legal basis for processing your personal data. Where we rely on legitimate interests for processing, the table explains the relevant legitimate interest.

Personal data

Purpose of processing

Legal ground for processing

Contact details

We use these to keep you informed about the status of your application 

Performance of a contract

Experience, skills and qualifications on CV

We use this information to consider your application against the requirements of the job you have applied for

Performance of a contract

For our legitimate interests:

  • To select suitable employees, workers and contractors

Right to work information

We require this information to know whether we can legally employ you

Compliance with a legal obligation

Performance of a contract

Additional information such as:

  • whether you can drive

  • salary expectations

  • notice period

  • references from third parties

  • professional memberships

We use this information to consider your application against the requirements of the job you have applied for

Performance of a contract

For our legitimate interests:

  • To select suitable employees, workers and contractors

Diversity monitoring information:

  • Health data, including disability information*

  • Information regarding pregnancy and maternity*

  • Age and date of birth

  • Marriage or civil partnership status*

  • Gender

  • Information on gender reassignment*

  • Data revealing race, religious beliefs or sexual orientation*

We use this information to evaluate the success of our work to attract diverse applicants into our business 

For our legitimate interests:

  • To review equality of opportunity or treatment

*For special categories of information:

  • To review equality of opportunity or treatment

To exercise or perform employment law rights or obligations

Medical information relating to a disability*

We use this information to establish if you require any special adjustments to our recruitment or interview process

 

We also use this information to establish whether you will be able to carry out a function that is intrinsic to the particular work

 

If you have accepted an offer of work from us that is subject to such a check: assess your fitness to work via a health questionnaire or medical report

Performance of a contract

To comply with a legal obligation

For our legitimate interests:

  • To select suitable employees, workers and contractors

*For special categories of information:

  • To exercise or perform employment law rights or obligations

Shortlisting decision making and interview feedback, decision to offer a job

We use this information to make a decision about whether to offer you a job

Performance of a contract

For our legitimate interests:

To select suitable employees, workers and contractors

 

The table above identifies the personal data that we may need to enter a contract with you. If you do not provide this information, we may not be able to proceed with the recruitment process or enter into a contract with you.

 

In some circumstances, the provision of your personal data is a statutory requirement. This includes:

  • Documentation confirming your right to work in the UK – if you don’t provide this, we may not be able to enter into a contract with you.

 

Transferring your personal data outside the UK

Our ATS is located in the UK, and hosts and processes data using UK-based data centre providers, so your personal data will not be sent outside of the UK. However, as part of the support and management provided by our ATS, they may occasionally use communication tools such as Slack and ClickUp that are based in Europe and may hold personal data (limited to names and email addresses) from time to time. 

How long do we keep your data?

If you are not successful in being offered a position with us, we will retain your personal data for six months after processing for the following reasons:

  • To allow us to establish, exercise or defend legal claims; and

  • For our legitimate interests – to enable us to reconsider your application if a suitable position becomes available again.

 

We will e-mail you before your personal data is destroyed to ask you if you would like us to retain it for a longer period so that we can continue to consider you for suitable vacancies. We will only keep your personal data after six months from last processing if we obtain your consent to do so. 

Automated decision-making

We do not envisage taking any decisions about you based solely on automated processing (i.e. without human involvement) which have a legal or similarly significant effect on you.

Access to your personal data and other rights

Under the data protection legislation, you may have certain rights as regards your personal information. These may include:

  • Receiving certain information about our processing;

  • Requesting access to your personal information that we hold (often known as a data subject access request);

  • Requesting transfer, correction, deletion, restriction of processing;

  • Objecting to processing;

  • Objecting to decisions based solely on automated processing, including profiling;

  • Being notified of a personal data breach;

  • Complaining to the Information Commissioner's Office; or

  • Withdrawing your consent to processing (if we process your personal information on the basis of your consent).

No fee usually required

You will not normally 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. Alternatively, we could refuse to comply with your request in these 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 your personal information (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 speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

To submit a request, please contact us as set forth in the 'Contacting Us' section below.

If you wish to exercise any of your rights, contact our recruitment team at recruitment@lastmile-group.com

 

Updates to this notice

This notice is subject to occasional revision. If we decide to change this notice, we will provide a copy of the updated notice to you.

 

Contacting us

If you have any questions about this notice please contact our Data Protection Officer: dataprotection@lastmile-group.com