Recruitment Candidate Privacy Notice

1. Overview

We are committed to protecting and respecting your privacy.

This Privacy Notice sets out the basis on which your personal data will be processed by us. We are committed to protecting your personal information and to being transparent about what information we hold.

The Great American European Division consists of Great American International Insurance (UK) Ltd (“GAUK”), Great American International Insurance (EU) DAC (“GAEU”) and Great American Europe Limited (“GAEL”), (referred to in this document as “the Companies”, “we”, “us”, “our” etc.)  GAUK and GAEL’s registered office is at 32 Queen Square, Bristol, BS1 4ND.  GAEU’s registered office is The Station House, Dublin Road, Malahide, County Dublin, Ireland.

For the purpose of the UK Data Protection Act (“DPA” 2018) and the Irish Data Protection Act 2018 which align to the European General Data Protection Regulations (“the GDPR”), the entity you are applying to (being GAUK, GAEU or GAEL) is the Data Controller.  If you are applying to GAUK or GAEU, then GAEL will act as a Data Processor in the recruitment process.

This privacy notice describes how we collect and use personal information about you during the recruitment process and applies to all candidates.

This Privacy Notice is for information only, it is not a contractual agreement.

1.1 Application and purpose

This Privacy Notice will apply to you if you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be obtained and used, namely for the purposes of the recruitment exercise, and for how long it will usually be retained.

2. Data Protection Principles

We will comply with data protection law and principles, which means that your data will be:

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and kept up to date;
• kept only as long as necessary for the purposes we have told you about; and kept securely.

3. Your data

3.1 Data we collect from you

When you apply for a role with us, either directly or via a recruitment agency, we may collect the following data during the recruitment process:

• Your full name
• Your address
• Your contact phone numbers
• Your email address
• Information about your legal right to work in the country where the position is based
• Your career history (via your CV or other application)
• Your education history and details of any professional memberships, accreditations etc.
• Details of your skills, knowledge and experience relevant to the vacancy

Later in the application, we may also collect:

• professional conduct and standing, credit status (such as identity checks, bankruptcy/court orders etc.); legal/ employment restrictions on your ability to perform the role
• details from your passport, visa, etc. relating to your right to work
• health and ability to perform the role in question
• employment / academic records as part of our referencing process, usually covering the previous five years
• information to establish you as an employee, such as bank details, national insurance number, emergency contacts and other details required to process your pay and benefits and protect you as an employee
• your driving licence details
• your emergency contact details
• your date of birth.

We may also collect, store and use the following “special categories” of more sensitive personal information:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
• Information about your health, including any medical condition, health and sickness records; and
• Information about criminal convictions and offences.

3.2 How we collect your personal data

We may collect the data listed above through a variety of sources:

• From you in your CV, covering letter or application form, during your interview and other selection activities and as part of any pre-employment checks etc.
• From recruitment agents or other referral sources
• From publicly available information such as on social media platforms, such as LinkedIn
• From your employment referees
• From other third parties used in (post-offer) pre-employment screening such criminal record checks, checks of academic or professional qualifications, identity and credit checks. These will be explained to you in more detail at the offer stage.

 4. How we use your data

 4.1 Purpose and lawful basis for processing your data

In order to comply with various legal obligations as well as ensure that candidates are suitable for the roles they are applying for, it is necessary to collect and process personal data.

4.2 How we will use information about you

We will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the work/role;
• Carry out background and reference checks, where applicable;
• Communicate with you about the recruitment process;
• Keep records related to our hiring processes;
• Comply with legal or regulatory requirements.

We collect and process your information where it is necessary in order to take steps, at your request, prior to our potentially entering into a contract of employment with you.  We may also process some information under legitimate interests, or consent basis, where we deem it is suitable to do so.  Certain data will be processed because we are legally required to.

Having received your CV and covering letter or your application form (including any test results as appropriate), we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role/work. If we decide to offer you the role/work, we will then take up references and inspect your original right to work documentation. We will also carry out additional pre-employment checks which may include (depending on the role) a criminal record check, an identity check, a credit check and/or verification of your qualifications and accreditations. Additional checks may be required for certain roles subject to regulatory approval. We will confirm what checks will be undertaken for you at the offer stage.

4.3 If you fail to provide personal information

If you fail to provide information when requested which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application successfully.  For example, if we require a criminal record check or references for this role and you fail to provide us with relevant details, we may not be able to take your application further.

4.4 How we use particularly sensitive personal information

We may collect sensitive ‘Special Category’ personal information in the following ways:

• We will use information about your disability to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview or as appropriate.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or sexual orientation, only as part of our diversity and inclusivity monitoring and reporting.

Such information is kept securely away from your application data and is not used in order to make any decisions about your suitability for the role.

After an offer has been made (or earlier at your request) we may also use data about your health (in particular about any disability) to establish your ability to undertake the role and any reasonable adjustments we can put in place to support you.

At a later stage in your application (usually after you have accepted an offer with us) and as indicated above, we may use other sensitive personal information as part of our pre-employment screening to assess your suitability for the role. This may include details of

• professional conduct and standing, credit status (such as identity checks, bankruptcy/court orders etc.); legal/ employment restrictions on your ability to perform the role;
• unspent criminal convictions and offences;
• employment / academic records as part of our referencing process, usually covering the previous five years.
• information to establish you as an employee, such as bank details, national insurance number, emergency contacts and other details required to process your pay and benefits and protect you as an employee.

Any information we require at this later stage of your application will be explained fully to you at the time. No third parties are contacted for any information not in the public domain without you being advised in advance.  In all cases, we have in place an appropriate safeguards for the protection of such data which we are required by law to maintain.

5. Transferring Your Data

 5.1 Sharing your personal data

During the recruitment process we may share your personal data with third parties in order to complete pre-offer screening processes such as a criminal record check.

We will not share your data with any other third party, except as allowed for in other privacy policies or required by law.  We do not sell your personal data to third parties under any circumstances.

5.2 Transfer of personal data to countries outside of the EEA

Countries within the European Economic Area (EEA) are governed by the GDPR, and aligned local laws, and therefore if any of your personal data is transferred to third parties within the EEA they will be required to comply with and safeguard your data in line with the UK’s DPA 2018.

The Companies’ ultimate parent is the American Financial Group, based in Cincinnati, Ohio.  Personal data may be transferred to this location, under the protection of Standard Contractual Clauses and adequate safeguards.  It is not envisaged that your data will be transferred to other countries outside of the EEA, however, should this is necessary (in order to fulfil our contractual obligations or for legal reasons), your data will only be transferred to third parties whose data protection laws have been assessed as adequate by the EU or where we deem adequate safeguards are in place.

6. Keeping Your Data

If your application is unsuccessful, we will keep your personal data for a period of 1 year after the recruitment process for the role that you have applied for comes to an end.  This is so that we can maintain accurate records of our recruitment processes.  All data will be securely destroyed when it is no longer required.

If you exercise your right to erasure (see section 8.1.4), we will continue to hold some data (your name and the role that you applied for) for our record keeping purposes and as required by law.

7. Data 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 those employees, 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.

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

8. Your rights regarding your personal data

Under the DPA 2018, you have a number of rights regarding your personal data:

8.1 Right to be informed

This policy sets out the information you are entitled to receive regarding the personal data that we collect and store for you

8.2 Right of Access

You have the right to obtain confirmation that your data is being processed as well as access to the personal data that we hold for you.

Where you make such a request, we will respond as soon as possible and at the latest within one month of receipt of your request and this information will be provided free of charge.

If we consider that your request is unfounded or excessive, we reserve the right to charge a reasonable fee for providing such information.  We may also extend the time taken to respond to you fully.

8.3 Right to rectification

You have the right to have personal data rectified where it is inaccurate or incomplete.  You may put this request in writing to the Group Head of HR.  Where a request is made, the data will be rectified as soon as possible and at the latest within a month of receiving your request.

Where applicable, we will notify relevant third parties of any changes to ensure that the data they are processing is rectified.

8.4 Right to erasure

You have the right to have your personal data erased if it is no longer necessary in relation to the purpose for which it was collected/processed.  Where possible we will comply with all requests to erase your data, save for data that is necessary to meet any statutory requirements or our record keeping purposes.

Where we have transferred your personal data to third parties, we will inform them of this erasure.

8.5 Right to restrict processing

You have the right to request that we restrict processing your personal data if you believe that the data we hold is inaccurate.  You can request that we restrict processing whilst we verify the accuracy of data that we hold.  You may also request that we restrict processing if you have issues with how your data is being processed.  This restriction may be put in place whilst we consider whether our legitimate grounds to processing your data supersede your request for restriction.

Where we have transferred your personal data to third parties, we will inform them of this restriction.

8.6 Right to data portability

You have the right to receive a copy of your personal data and/or have this data transmitted to another data controller.  We will comply with any such requests as far as is reasonable but it may not be possible to transmit data in a way that is compatible with systems of another controller.

8.7 Right to object

You have the right to object to us collecting, storing and processing your personal data.  Where an objection is made to us processing your data for direct marketing purposes, we will deal with this immediately and cease all marketing activities.

Where you object to us processing the data for legitimate interest grounds, we will consider this objection and will cease processing where possible.  In some circumstances our legitimate grounds for processing your data may override your request.

8.8 Rights related to automated decision making including profiling

We do not operate any systems using automated decision making or profiling in relation to our recruitment processes.

9. Contacts

If you have any questions or concerns regarding this policy or the personal data that we hold and process for you, please contact the Group Head of HR.

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.

This Recruitment Candidate Privacy Notice was last updated 14^th August 2023.