YEOMANS LIMITED RECRUITMENT PRIVACY POLICY

1. Introduction - What is the purpose of this document?

1.1. Yeomans Limited is a “Controller” in relation to personal data. References to “Yeomans”, “we”, “us”, “our” means Yeomans Limited. Being a data controller means that we are responsible for deciding how we hold and use personal information about you. We are sharing a copy of this privacy notice with you because you are applying to work with us (whether as an employee, worker or contractor). This policy makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulations (UK GDPR).

1.2. By applying for a vacancy with us you agree that your personal information will be used by us as described in this policy.

1.3. For further information about how to contact us, please see the section headed, Our Data Protection Officer and your queries and right to complain.

2. Data protection principles

2.1. We will comply with data protection laws and principles, which means that your data will be:

• Processed, fairly, lawfully 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 compatible with those purposes.
• Relevant to the purpose 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.
• Kept securely.

3. The kind of information we hold about you

3.1. We will make sure that we only collect the minimum personal data we need from you for the recruitment process. If you or any third party (e.g. a recruitment agency) provides us with information that is excessive, we will dispose of it securely and will not keep a copy.

3.2. If you make an application for work with us, at difference stages of the recruitment process, we may collect, store, and use the following categories of personal information about you:

• Your full name
• Title
• Home address
• Telephone number
• Personal email address
• Date of birth
• Gender
• Details of education and qualifications
• Employment history
• Start date and, if different, the date of your continuous employment
• Details of driving history
• Criminal record history
• Recruitment information including copies of right to work documentation, (which may include your HMRC P45, national insurance card, passport, utility bill or proof of address), references and other information included in a CV and/or cover letter or as part of the application process
• Notes of your interview appraising your performance
• Information collected about you as part of background checks including a DBS check, driving licence check and adverse financial checks
• Evidence of your right to work and live in the UK which may include a valid passport, government share code or valid work permit
• Bank account details, payroll records and tax status information
• Marital status and dependants
• Next of kin and emergency contact information
• Copy of driver's licence and details of driving history

3.3. We may also collect, store and use the following types of more sensitive personal information:

• Information about your health, including any medical condition, health and sickness records.

3.4. The law defines this personal data as "Special Category Data". This is information that is particularly sensitive and, as such, requires a higher level of protection. We need to have further justification for collecting, storing and using this type of personal data. We have in place appropriate safeguards to protect it and will only use it for the following circumstances: In limited circumstances, with your explicit written consent.

• In limited circumstances, with your explicit written consent.
• Where we need to carry out our legal obligations or exercise rights in connection with the recruitment process.
• Where it is necessary in the public interest, such as for equal opportunities monitoring.

3.5. Less commonly, we may process this type of information where it is necessary in connection with legal claims or to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

3.6. We may also process such information about applicants or former applicants in the course of legitimate business activities with the appropriate safeguards.

4. How is your personal information collected?

4.1. We collect personal information about candidates from the following sources:

• Directly from you, the candidate.
• Recruitment agencies which you have shared your information with and who have sought your permission for your personal information to be shared with us.
• Your named referees, from whom we collect the following categories of data: name, email address and telephone number.
• Data from a publicly accessible source, for example LinkedIn, and other Social Media sites.
• Background checking providers if you are offered a position with us.

5. How we will use information about you

5.1. The primary purpose that we need to process your Personal Data is to perform our legal obligations. In some instances, we may use your Personal Data where it is necessary in our legitimate interests or those of third parties, provided your interests and fundamental rights do not override those interests.

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

• Process and progress your recruitment application.
• Assess your skill, qualifications, and suitability for the role.
• Make a decision about your recruitment or appointment for this vacancy and to draft the relevant documentation.
• Consider you for any upcoming vacancies that are suitable (if you have opted in to be contacted in respect of subsequent vacancies)
• Fulfil our legal obligations which may include carrying out our obligations arising from any contracts entered into between you and us to provide you with information that you request from us, checking you are legally entitled to work in the UK.
• Carry out background checks to ensure your suitability for the role.
• Communicate with you about the recruitment process.
• Keep records relating to our hiring processes.
• Provide general and statistical information to help us develop our processes.
• Make up part of your employee personnel records if your application is successful and under the terms of your employment.
• Comply with legal or regulatory requirements to include compliance with equality laws.

5.3. It is in our legitimate interests to decide whether to appoint you to the role which you have applied for since it would be beneficial to our business to appoint someone to that role.

5.4. We also need to process your personal information to decide whether to enter into a contract of employment with you.

5.5. Once we have received your CV and covering letter, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we 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. If we decide to offer you the role you will be required to undergo a background check

6. Equal Opportunities

6.1. We are required by law to make basic documentation checks on every successful candidate. Please note that we will ask you to provide evidence of your eligibility to work in the UK.

• Such evidence might include your passport, birth certificate and official document with NI number or share code.

7. If you fail to provide personal information

7.1. 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 will not be able to process your application successfully, or if you fail to provide us with relevant details to carry out background checks, we will not be able to take your application further or we may be prevented from complying with our legal obligations (such as our obligations under employment law).

8. How we use particularly sensitive personal information

8.1. We will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.

9. Information about criminal convictions

9.1. We will process information about criminal convictions to assess your suitability for the role.

10. Automated decision-making

10.1. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

11. Data Sharing

11.1. We will only share your personal information with the following third parties for the purposes of processing your application

• Companies who we use to provide background checking services and driving licence checks.
• Companies who support us with the recruitment process such as e-signature providers.
• Insurance providers if an issue arose as a result of a driving licence check.

11.2. All our third-party service providers and other entities in the group are required to take appropriate security measure to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

11.3. In addition, we will disclose the Personal Data we hold about you to third parties where required by law, where necessary to administer our relationship with you or where we have another legitimate reason to do so.

12. The lawful basis on which we handle your personal data

12.1. Data protection law sets out a number of conditions which organisations can rely on in order to lawfully handle Personal Data. The conditions we rely on are as follows:

• Legitimate interests
  The law permits us to handle your Personal Data where necessary in our legitimate interests provided that this isn’t outweighed by your interests. Many of the purposes we handle your Personal Data, described above, fall into this category as they are essential activities which enable us to manage our recruitment process and to improve our processes. We may, if necessary, also use your Personal Data to defend our legal rights or to obtain legal advice and to manage any complaint that you might have. We ensure that your rights and interests are protected when we do this.
• Consent
  We are permitted to use your Personal Data when you give us your consent for us to do so. For example, if you ask us to keep you informed about future vacancies when they arise.
• Required by law
  We will, if required by law, disclose your Personal Data for example in response to a court order. We will disclose your Personal Data if requested by a law enforcement agency or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or as otherwise permitted or required by law and consistent with legal requirements.

13. Data security

13.1. 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 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.

13.2. Where third parties process your personal information on our behalf, we will ensure that a written Data Processing Agreement or appropriate contract is in place.

13.3. 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.

13.4. For further details on how we keep your data secure please contact the Data Protection Officer at dataprotection@yeomans.co.uk .

14. How long will we use your information for?

14.1. We will retain your personal information for a period of 6 months after we have communicated to you our decision about whether to appoint you to the role. We retain your personal information for that period so that 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 data retention policy.

14.2. If you are appointed to the role, we will retain this information on your employee file in accordance with our data retention policy and applicable laws.

14.3. If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

15. Your Rights - Rights of access, correction, erasure, and restriction

15.1. Data protection laws give you a number of rights in relation to your Personal Data. We will consider every request, however, please be aware that these rights are not always absolute and may not always apply.

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

• Right to be informed. You have the right to be informed about the collection and use of your Personal Data. This right includes information relating to, the purposes we process your Personal Data, the time period we retain your Personal Data for and who your Personal Data is shared with.
• 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 correction/ 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 your 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 (see below).
• Object to processing of your personal information where we are relying on 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, for example if you want us to establish its accuracy or reason for processing it.
• Request the transfer (portability) of your personal information to another party.
• Rights related to automated decision-making including profiling. You have the right to ask us when evaluating you (for example performance at work) that we don’t base any decisions solely on an automated process where such decision would have a legal or similarly significant effect on you and to have any decision reviewed by a relevant member of staff.

15.3. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer at dataprotection@yeomans.co.uk.

16. Right to withdraw consent

16.1. When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact hr.admin@yeomans.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

17. Data Protection Officer

17.1. We have appointed a Data Protection Officer (DPO) to oversee compliance with the privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at dataprotection@yeomans.co.uk.

18. Right to Complain

18.1. You have the right to make a complaint at any time to the Information Commissioners Office (ICO) (www.ico.org.uk) who is responsible for data protection issues in UK.

19. Changes to this Privacy Notice

19.1. We may update this privacy notice at any time. If we do, we will make the updated version available to you.

Policy reviewed: March 2025