Our privacy notices

LWM Traded Services is committed to protecting and respecting your privacy. This notice sets out the basis on which any personal data we collect for the purpose of recruitment will be processed. This privacy notice tells you what to expect when LWM Traded Services collects your personal data.

LWM Traded Services is the Data Controller for the personal data processed as described in this notice, unless otherwise stated. Our contact details are provided below.

This notice applies to anyone applying for a position with LWM Traded Services or with Lichfield District Council. LWM Traded Services provide recruitment services for Lichfield District Council. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time, details of which are found at the end of this document. It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. 

The personal data we collect

We collect personal data directly from you as follows:

• contact details such as name, title, address, telephone numbers, and personal email addresses,
• personal information such as age, date of birth, gender (if included in CV),
• copies of identification documents such as driving licence, passport,
• evidence of how you meet the requirements of the job, including CVs and references,
• evidence of your education and employment history,
• information about your health, including any medical needs or conditions (for reasonable adjustments at interview),
• information relating to the interview process, personality tests or capability tests (where appropriate and relevant to the role),

Please note this list is not exhaustive but gives an indication of the data we collect. We will also collect subsequent information should you be successful at interview to enable LWM Traded Services to process your application to employment status.

Source of the personal data

We collect personal information about candidates through the application and recruitment process, either directly from candidates, former employers or recruitment agencies.

If you fail to provide personal information 

If you fail to provide certain information when requested, we may not be able to assess your capability for the position. This could affect your ability to be employed by LWM Traded Services.

Our legal basis for processing your data 

We will only use your personal information when the law allows us to do so.  Most commonly we will use your personal information in accordance with the following conditions for processing: 

• Consent (Article 6 (1a)) –we process your personal data based on your consent. 
• Contract (Article 6(1b)) – We process your personal data based on our proposed contractual employment relationship.  
• Legal obligation (Article 6 (1c)) – We process your personal data based on a law. 
• Legitimate interests (Article 6 (1f)) – We process your data for our legitimate interest and your interests and fundamental rights do not override those interests. 

Purposes of our processing and our legal basis

We may use your personal information for the following purposes: 

• make a decision about your recruitment or appointment (Article 6(1)(b),  
• administering and processing your application (Article 6(1)(b),
• check you are legally entitled to work in the UK (Article 6(1)(c),
• to provide reasonable adjustments relating to health or disability during the recruitment process (Article 6(1)(c) & Article 9(2)(b),
• communicate with you, other LWM Traded Services employees and third parties (e.g. referees, including former employers & external recruitment agencies) (Article 6(b)),
• comply with applicable laws, such as employment laws, and employment-related requirements (Article 6(c)),
• respond to and comply with requests and legal demands from regulators or other authorities (Article 6(c)).

Please note this list is not exhaustive but gives an indication of the purposes for processing activities we undertake.

Change of purpose 

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

Who we share your data with?

We only share your information where we are strictly able to and only in accordance with Data Protection legislation. We may share your personal data in the following circumstances:

• Within LWM Traded Services,
• With Lichfield District Council (for LDC roles)
• With relevant recruitment agencies,
• With relevant job sites, such as Indeed or LinkedIn etc,
• Where we are using contracted service partners for services such as IT hosting companies and IT services companies,
• To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person,
• To enforce or apply our Terms of Service or other agreements or to protect LWM Traded Services and its customers (including with other companies and organisations for the purposes of fraud protection and credit risk reduction),
• To any other person with your consent to the disclosure.

Should you be successful at interview LWM Traded Services will undertake various checks, such as right to work, DBS etc, which will be fully explained to you prior to such checks taking place.

A list of third parties who we may share your data with can be obtained from our Data Protection Officer.

Data security 

We have put in place appropriate security measures to prevent your personal information from being accidently lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to our 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 breaches and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. 

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

International transfers

Our data is typically hosted in the UK and other parts of the EEA, there are however some of our contracted technical service providers that process from outside of the EEA. Where these transfers and any other transfer than may occur in the future are concerned, we ensure that there is a legal basis for the transfer and a lawful transfer mechanism in place prior to any transfers in place.

Any such transfers currently done are done using either a transfer to a country with an adequacy ruling, or if a third country, using the relevant transfer mechanism such as the European Commission Standard Contractual Clauses, or the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses and the relevant transfer impact assessments.

How long do we keep data we collect?

We will retain your personal information for a maximum period of 12 months after we have communicated to you our decision about whether to appoint you. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our retention policy.

If you commence employment with LWM Traded Services, your personal data will be processed in accordance with your employment contract, our employee privacy notice and our other applicable policies.

Your data protection rights

It is important that the personal information we hold about you is accurate and current.  Please keep us informed if your personal information changes.

Your rights in connection with personal information 

Under certain circumstances, by law you have the right to: 

Be informed of how your personal information is processed, by the provision of privacy notices such as this notice.

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. 

Request rectification of the personal information that we hold about you.  This enables you to have any incomplete or inaccurate information we hold about you corrected. 

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.  You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing. 

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 situation which makes you want to object to processing on this ground.  You also have the right to object where we are processing your personal information for direct marketing purposes. 

Request the restriction of processing of your personal information.  This enables you to ask us to suspend the processing of personal information about you. 

Request the transfer of your personal information to another party (data portability). 

Request a review of automated decision making, including profiling. This gives you the right to not be subject to a decision based solely on automated processing which has a legal effect on you.

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. If you make a request, we have one month to respond to you. Please contact our Data Protection Officer to exercise any of your rights.

Contact details

If you need further information or have any questions or complaints about our privacy notices or practices, please contact our Data Protection Officer (DPO) using the details below: 

Data controller

LWM Traded Services email: dpofficer@lwmts.co.uk

Your right to complain

We would encourage you to contact us, in the first instance, if you are unhappy with any aspect of the way in which we process your personal data. You can get in touch with our Data Protection Officer using the details provided above.

If you are not satisfied with the outcome of your complaint, you have the right to refer such matters to the ICO (www.ico.org.uk). It is worth noting the ICO expect individuals to exhaust the complaints process internally before referring complaints to them.  

Changes to this privacy notice

We keep our privacy notice under regular review, and it is subject to change at any time. We may also notify you in other ways from time to time about the processing of your personal data.