Data controller information: Gabriel Dawn Limited (“Gabriel Dawn”), 7 Bell Yard. London WC2A 2JR. The above business operates in the UK. The person responsible for Data Protection at Gabriel Dawn is Sam Dawn.
What is the purpose for collecting and processing personal data?
Gabriel Dawn processes data for the purpose of its own and its clients’ HR, recruitment and selection. Gabriel Dawn collects and processes personal data relating to job applicants, employees and clients. Gabriel Dawn is committed to being transparent about how it collects and uses personal data; and to meeting its obligations under the General Data Protection Regulation (GDPR). Gabriel Dawn will only process personal data where either consent has been obtained or where there is legitimate interest for HR and recruitment purposes and with the intention for either Gabriel Dawn or its clients to enter into a contract of employment with the data subject. Personal data will also be processed where there is a contract in place to do so. Where a candidate or employee is processed by Gabriel Dawn’s clients, the client privacy notice will also apply.
What information is collected?
Gabriel Dawn may collect the following information:
- Data subject name, address and contact details; including email address and telephone number(s);
- Details of qualifications, skills, experience and employment history;
- Information about remuneration, including benefit entitlements;
- Information regarding disability for which the company or its clients may need to make reasonable adjustments during the recruitment process;
- Information about entitlement to work in the UK;
- Equal opportunities monitoring information, including, but not limited to, information about your ethnic origin, sexual orientation, health and religion or belief.
- Interview notes and feedback
- Assessment notes and feedback
Gabriel Dawn may also collect personal data from other third parties, such as references supplied by former employers, information from employment background check providers including information from criminal records checks. Please note that Gabriel Dawn will only request information from third parties when permission has been sought to do so.
How is personal data collected?
Gabriel Dawn will collect data in the following ways:
- Careers online portals (extension to Applicant Tracking System)
- Job Boards such as Total Jobs, Reed, Monster, CV Library and Indeed
- Social Media platforms such as LinkedIn, Twitter, Facebook and Instagram
- Verbally either face to face or over the telephone
- Third party recruitment agencies
- Recruitment events such as open days
- Assessment centres
- Hard Copy CV’s or paperwork
Data from the above sources might be contained in application forms, CVs, online profiles, obtained from identity documents or collected through interviews or other forms of assessment, including online tests.
How will personal data be stored?
Data may be stored in the following places:
- Within Gabriel Dawn’s Applicant Tracking System. All data is hosted in controlled and secured in state of the art data centres.
- Within Gabriel Dawns’ survey database hosted on a secure server.
- Within Gabriel Dawn’s own secure servers.
Why does Gabriel Dawn process personal data?
Gabriel Dawn needs to process data for the performance of HR or Recruitment service contracts it has in place with its clients. We will also need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the UK before employment starts. Gabriel Dawn may also need to process data to respond to and defend against legal claims. For the purpose of recruitment, Gabriel Dawn may keep personal data on file in case there are future employment opportunities for us or our clients for which they may be suited. Data subjects are free to withdraw consent for processing at any time.
Who has access to data?
Personal information may be shared for the purposes of the recruitment or HR delivery exercise. This includes
- Gabriel Dawn Employees
- Representatives of Gabriel Dawn
- Representatives of clients
We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU and if we do, you can expect a similar degree of protection in respect of your personal information. Gabriel Dawn will share the minimum personal data required
How does Gabriel Dawn protect data?
The Company has internal policies and controls in place to ensure that data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
How long does Gabriel Dawn keep data?
Recruitment: Where a candidate is successful, personal data gathered during the recruitment process will be transferred to the personnel file or client and retained throughout employment. The periods for which data will be held will be provided in a new privacy notice relating to employment. Gabriel Dawn will also retain all successful candidate records. If an application for employment is unsuccessful, Gabriel Dawn will hold candidate details for consideration of future employment opportunities unless the candidate withdraws consent. HR Services: Any personal data received to enable Gabriel Dawn to undertake HR services on behalf of its clients will be retained for as long as required and in line with the client’s retention criteria. Where applicable and particularly in the case of recruitment, data subjects will be contacted periodically to request updated information. If consent is withdrawn, personal data is deleted or destroyed.
Rights of the Data Subject
Data subjects have a number of rights. They can:
- access and obtain a copy of data on request;
- require us to change incorrect or incomplete data;
- require us to delete or stop processing data, for example where the data is no longer necessary for the purposes of processing; and
- object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing.
- Request for transfer of data
- Request to be ‘forgotten’ and deleted
If a data subject would like to exercise any of these rights, they must contact the Gabriel Dawn team at mydata@GabrielDawn.com. If the data subject believes that Gabriel Dawn has not complied with their data protection rights, they can complain to the Information Commissioner.
What if no personal data is provided?
Data subjects are under no statutory or contractual obligation to provide data to Gabriel Dawn during the recruitment process. However, if they do not provide the information, Gabriel Dawn and its clients may not be able to process any HR or Recruitment activity that is applicable.
Automated Decision Making
It is necessary as part of some recruitment processing activity, to include partial automated decision making by way of electronic questioning. There is the option for human intervention at all times during the processing of data. Questions are only asked if the information is required as part of selection criteria and no other automated profiling occurs during the recruitment process.
Removal of your Information
A data subject can, at any time withdraw consent by contacting the individual client or the Gabriel Dawn team direct at mydata@GabrielDawn.com. Please note that this privacy notice may be updated and reviewed from time to time.