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In this Notice, when we refer to “TMK”, “we, us, or our”, we mean the entities set out below in the section Who are we? and when we refer to “you or your”, we mean the individuals who have applied or is applying for work with us (whether as an employee or through a contracting arrangement).
What is the purpose of this Notice?
This Notice will explain how we collect, use and share personal data for the purpose of our recruitment process and how long personal data will be retained for. If you provide personal data about other individuals to us, such as family, friends or other associates, you must seek their permissions and inform them in the first instance and share a copy of this Notice with them.
For the purposes of this Notice, any reference to “your information” includes personal data that you provided to us in relation to other individuals.
Who are we?
This Notice covers:
- Tokio Marine Kiln Group Limited and all its UK subsidiaries including:
- Tokio Marine Kiln Insurance Services Limited
- Tokio Marine Kiln Insurance Ltd
- Tokio Marine Kiln Syndicates Limited
- Tokio Marine Kiln Regional Underwriting Limited
- Kiln Pension Guarantee Limited
- Tokio Marine Europe Limited
- Tokio Marine Underwriting Limited
- Tokio Marine Asset Management (London) Ltd
- Tokio Marine Claim Service Europe Ltd
TMK is a data controller in respect of personal data which we receive in connection with our recruitment process. This means that we are responsible for deciding how we can use the personal data.
Data protection principles
TMK will comply with data protection law and principles, which means that your information 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 for only as long as necessary for the purposes we have told you about
- Kept securely
What kind of information do we hold about you?
Personal data means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
In connection with your application for work with us, we will collect, store, and use the following categories of personal data:
- The information you have provided to us in your curriculum vitae (CV) and covering letter
- The information you have provided on our application form, including your title, name, telephone number, personal email address, employment history, qualifications, eligibility to work in the UK, salary details and notice period
- Any information you provide on our application form which is non-mandatory, including disability, racial or ethnic origin, religion, sexual orientation, age and gender
- Any information that is provided to us by the recruitment agency such as your CV that includes name, education, qualifications and any work experience
- Any information you provide to us at any time during the application process, such as during an interview, including where applicable video interviews
- Any information on your medical condition or disability that you provide to us throughout the application process.
- Results of any verbal, numerical or psychometric testing where it is completed as part of the application process
- Any information that we collect as part of our background checks, including information about criminal convictions
How is your information collected?
We collect information concerning about our candidates from the following sources:
- You, the candidate
- The recruitment agency
- Our background check provider and credit reference agency in respect of background checks
- Disclosure and Barring Service in respect of criminal convictions
- Your named referees, from whom we collect employment and character information
How will we use your information?
We will use your information to:
- Assess your skills, qualifications, and suitability for the role
- Carry out background and reference checks, where applicable
- Communicate with you about the recruitment process
- Keep records related to our hiring processes
- Consider and determine what reasonable adjustments are required to be made, where you have disclosed a medical condition or disability to us
- Comply with legal or regulatory requirements
We need to process your information to decide whether to enter into a contract of employment (or other contract) with you. It is also in our legitimate interest to use the information to help us decide whether to appoint someone to a role that we are hiring for.
Having received your CV and covering letter and/or your application form and the results from any test that you may have taken as part of the recruitment process, TMK 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. If we decide to offer you the role, TMK will only take up references and background checks once an offer of employment has been made. Any offer will be subject to satisfactory background checks and references.
If you fail to provide your information to us
If you fail to provide certain 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. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use special categories of personal data?
Special categories of personal data, such as information about a person's health, disability, racial or ethnic origin and sexual orientation, require higher levels of protection.
We will use your special categories of personal data in the following ways:
- We will use information about your disability status to consider whether we need to provide reasonable adjustments during the recruitment process
- We will use information about your racial or ethnic origin and sexual orientation, for the purposes of diversity and inclusion
Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our legal obligations or exercise our rights in connection with your employment or where you have provided us with your consent to do so.
We will only collect and hold information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. We will use information about criminal convictions and offences in the following ways:
- To assess whether an individual is fit and proper to carry out their role
TMK is allowed to use personal data in this way and we have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.
Do we need your consent?
Under data protection laws, we do not always need your consent to collect and use your personal data. For example, we would not need your consent to collect and use your data process your information to decide whether to enter into a contract with you or where it is in our legitimate interest to use the data to help us decide on a hiring decision – see the section on How will we use your information?
Where we collect and use special categories of personal data (such as information about your health, disability, racial or ethnic origin and sexual orientation), we would need to fulfil an additional condition. Most commonly, we will rely on one of the following additional conditions:
- You have given us explicit consent. If we do so, we will provide you with full details of the data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You are under no obligations to provide the data and there will be no adverse consequences if you do not do so.
For example, we will ask for your explicit consent (where the law allows us to do so) whenever we collect and use your special categories of personal data for the purposes of monitoring diversity and equal opportunities. This includes data on your nationality, racial and ethnic origin, gender, sexual orientation, religion and disability as part of diversity monitoring initiatives.
- We must process the data in order to carry out our legal obligations or exercising specific rights in the field of employment law.
Before we collect and use information on criminal convictions, we will usually obtain your consent. Where applicable, we may also rely on our legal obligations or our rights to do so in connection with your employment.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why we share your information with third parties
We will share your information with the following third parties for the purposes of processing your application on our behalf:
- Net-Worx (2001) Limited (trading as Networx) who operates our recruitment platform
- Pearn Kandola LLP for any required psychometric testing
- Credence Background Screening Limited for background checks, if a conditional offer of employment is made
All our third-party service providers and other entities in the group who handle your information on our behalf are required to take appropriate security measures to protect your information in line with our policies. We do not allow our third-party service providers to use your information for their own purposes. We only permit them to process your information for specified purposes and in accordance with our instructions.
If a conditional offer of employment is made, we will arrange for pre-employment medical checks to be conducted by medical service providers appointed by us. These medical service providers will act as independent controllers of your information when conducting pre-employment medical checks as they will determine the purposes and means of the processing of your information. They do not process your information on TMK’s behalf and they are responsible for their own use of your information. You should refer to their privacy notices for more information about their practices.
We have put in place appropriate security measures to prevent your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained by contacting us at firstname.lastname@example.org.
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.
How long will we use your information for?
If you are employed by us following your application, your information will be retained according to our Employee Privacy Notice which will be notified to you. Otherwise, we will retain your information for a period of 6 months after we have communicated to you our decision about whether to appoint you to the role or after 6 months of inactivity. We retain your 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 information in accordance with our data retention policy and/or any applicable laws and regulations.
If we wish to retain your 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 consent to retain your information for a fixed period on that basis.
Rights of access, correction, erasure, and restriction
Your rights in connection with your information
Under certain circumstances, by law you have the right to:
- Right of access You have the right of access to your information. If you would like to exercise this right, you should email us at email@example.com.
- Right of erasure or rectification If you feel that any information that we hold about you is inaccurate, you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where the information is no longer needed by us, where we are unlawfully processing your information or where our processing of your information is based on your consent. Please note that there may be circumstances where you ask us to erase your information but we are legally entitled to retain it. Where we have disclosed your information to another person, we will take all reasonable steps to inform those with whom we have shared your information about your request to erase or correct/ rectify your information.
- Right to object to or restrict processing You have a right to object to our processing of your information where our processing is based on legitimate interests. This includes the right to object to any direct marketing we may undertake and to any automated decisions based on profiling which we may carry out. You also have a right to request that we restrict processing your information while we consider your request to erase or rectify your information. Again, there may be circumstances where you object to or ask us to restrict our processing of your information but we are legally entitled to refuse that request.
- Right to portability You have a right to receive your information that you have provided to us in a commonly used, machine readable format in order to transfer it to another data controller. This is called a data portability request and is only available where we process your information on the basis of your consent or for the performance of our contract with you.
- Right to withdraw consent You have the right to withdraw your consent for the processing of your information where the processing is based on consent.
- Right of complaint You have a right to lodge a complaint at any time about how we are handling your information with the UK Information Commissioner's Office who can be contacted at firstname.lastname@example.org. However, we hope that before you do so, you will first contact us at email@example.com to let us know. We wish to assure you that we are committed to working with you to settle any concern or complaint your may have about how we handle your information.
If you would like to find out more about your rights, please email us at firstname.lastname@example.org.
How can you contact us?
If you have any questions about this Notice or how we handle your information, please contact us at DPO@tokiomarinekiln.com . 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.