Job Candidate Privacy Notice
Version: 2.1
Date adopted: 5 July 2024
This privacy notice provides information about how we use and share the personal data that we obtain during the job application process.
| In brief |
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We use your personal data to manage the recruitment process and perform background checks on you, including credit checks and criminal record background checks. There are also a few other purposes for which we may use your personal data; please see section 2 for more details.
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You have the right to object to our use of your personal data. Please see section 9 to find out more.
This privacy notice covers the following topics:
- Who we are and how can you contact us?
- What do we use personal data for?
- What kinds of personal data do we use, and where do we get it from?
- How long is the personal data kept for?
- What is our legal basis for handling personal data?
- Who do we share the personal data with?
- Where is the personal data stored and sent?
- Is the personal data used to make decisions about you or to profile you?
- What are your rights?
- Who can you complain to if you are unhappy about the use of your personal data?
If you become employed as a result of your application, your personal information will be processed in accordance with the TransUnion Europe People Privacy Notice.
1. WHO WE ARE AND HOW CAN YOU CONTACT US?
About us
This privacy notice relates to the TransUnion group companies operating in Europe, which we refer to as “TransUnion Europe”. Our regional headquarters is at One Park Lane, Leeds, West Yorkshire LS3 1EP. Some of the members of TransUnion Europe are listed in section 6 below. TransUnion Europe is part of the wider TransUnion group, but this privacy notice only covers the activities of TransUnion Europe.
The TransUnion company to which you are applying is the controller of the personal data we hold about you for the recruitment process. The controller is responsible for ensuring that the personal data is used fairly and lawfully and is the company against whom you can exercise the rights referred to in section 9.
Joint controllers
In some cases TransUnion companies may act jointly with one or more of the other TransUnion companies when making decisions about your personal data. In particular, this will often happen when TransUnion companies are sharing data with each other.
Where our group companies make decisions jointly, the colleagues involved will ensure that each company complies with the applicable data protection rules. You can contact us if you want to enquire about any of our group companies or exercise any of your rights in respect of your personal data.
Contact details
You can contact us about issues relating to personal data, including the contents of this notice, and the exercise of your data protection rights, by emailing us at: ukrecruitment@transunion.com.
2. WHAT DO WE USE PERSONAL DATA FOR?
This section explains the purposes for which we use personal data about you. More detail about the types of personal data that we might use for these purposes can be found in section 3 below.
Managing the recruitment process
We use personal data:
- to communicate with you and (on a strict need to know basis) relevant TransUnion personnel involved in the recruitment process, and relevant third parties, for the reasons set out in this privacy notice;
- to record and demonstrate how we have conducted the application and recruitment process and arrived at our decision regarding your application.
Employment screening checks
Due to the nature of its business, TransUnion holds highly confidential data within its systems and records and is subject to stringent legal and regulatory responsibilities.
To protect TransUnion’s interests, and those of its clients, partners, and other stakeholders including consumers and third parties, TransUnion undertakes identity verification checks and employment screening. These checks are mandatory and will generally need to be completed before commencement of any employment.
Completion of these checks will require you to present certain documentation or provide additional details, and may require signed authorisation or acknowledgement from you – further details will be provided with any offer of employment.
We are mindful of your privacy so we will only undertake these checks according to the appropriate stage of the application. These checks include:
If we decide to make you an offer of employment:
| Type of check | Description |
|---|---|
| Your credit file, fraud prevention and identity verification checks | We will check your financial situation and history in your credit file held by a credit reference agency. This includes any shared credit, any court judgments or orders, bankruptcy, individual voluntary arrangements or similar events). This search leaves a “footprint” on your credit file. We will also check your details on one or more fraud prevention databases such as the Cifas Insider Threat Database. |
If you accept an offer of employment:
| Type of check | Description |
| Right to work checks | To comply with our legal obligations concerning migrant workers, we will need you to provide certain documentary evidence. Where eligibility is unclear from the documentation you provide, we may contact the relevant public authority to confirm eligibility. |
| Criminal background checks | Where permitted in accordance with local legal requirements, we will perform a check on whether you have any criminal convictions that affect your suitability for the role. We will use a third party for this purpose. For the UK, a check is made with the Disclosure and Barring Service (if you live in or the job is in England and Wales), or Disclosure Scotland (if you live in or the job is in Scotland). A higher level of check may be needed for certain roles, for example Senior or Certified Managers under the FCA SMCR regime. |
| References | We will check your employment and educational references for a period up to the preceding 10 years. |
| Qualifications and memberships | We will check your qualifications and relevant trade or professional memberships. Where the information you provide is incomplete, we may seek confirmation directly from the issuing body. |
| Public register checks | We will check whether there are any entries against you in public registers such as the FCA’s register of authorised persons (restrictions or suspensions), the US Office of Foreign Assets Control and HM Treasury financial sanctions lists (sanctions and asset freeze targets), and the Companies House register (disqualified directors). |
| Fraud prevention checks | We will conduct a further check of your details against one or more fraud prevention databases such as the Cifas Internal Fraud Database. |
Where the application is for a senior management or executive role, we also review publicity and profile information available about you through internet search engines, for relevancy to the standards of integrity and conduct required of that role.
Should you become employed by TransUnion Europe, certain repeat screening checks will be undertaken at appropriate intervals, details of which are provided when employment commences.
Making reasonable disability adjustments (as applicable)
We will process your personal data to ensure appropriate arrangements are in place throughout the recruitment process and, if your application is successful, to prepare for you commencing employment.
Monitoring to ensure our recruitment practices meet equal opportunities obligations
We are legally required to ensure that all job applicants are given fair and equitable opportunities. We therefore require that you provide certain information in the job application form to help us monitor our practices for compliance with this requirement, and to enable us to make reasonable adjustments through the recruitment process.
If any offer of employment is taken up, we continue to keep this information throughout the employment relationship to help us to maintain fair treatment for our colleagues. This is only done to review our practices in relation to treatment across colleague groups, rather than to track your treatment and make decisions about you at individual level.
If you have any concerns around this or require us to cease using your personal information for this purpose, please email us at ukrecruitment@transunion.com.
Legal and regulatory purposes
We may use your personal data to respond to and defend any legal claims that may arise out the recruitment process. We may also provide information to law enforcement agencies where they request this, or of our own choice where we consider there is a compelling reason to do so to protect our workers, visitors, customers, or our general business interests.
3. WHAT KINDS OF PERSONAL DATA DO WE USE, AND WHERE DO WE GET IT FROM?
We obtain and use information from various different sources. These are summarised in the following table.
| Type of information | Description | Source |
|---|---|---|
| Name and contact details | This is basic personal data about you, and how to get in touch with you. It includes your current home address, email addresses and telephone numbers. | This information is typically obtained directly from you (and/or the recruitment agent involved where applicable) in the application form, from the checks described above, from interviews, or as otherwise notified to you within the application process. |
| Date of birth | We collect your date of birth to ensure we attribute our records and any employee checks to the correct person and, where needed, to identify whether you are within a qualifying age range. | |
| Driver information | We require proof of driving and vehicle insurance eligibility where driving is relevant to the role or involves a company vehicle. | |
| Criminal convictions information | Please see section 2 above for an explanation of criminal background checks. | |
| Right to work information | You will be asked to provide relevant documentation for us to check your eligibility to work in the country you reside in. | |
| Other background information and checks | You will be asked to declare certain information about yourself, such as your financial history (including whether you have had any bankruptcy orders or court judgments made against you), and this information will be checked against other sources. Please see section 2 above for more details. | |
| Other application details | This will include your previous education and work history including work references, qualifications and where applicable, professional memberships, your reasons for applying and suitability for the position and other details you provide in the application form and during interview. | |
| Disability (where applicable) | This is information about any disability you might have. | |
| Equal opportunities monitoring | Please see the explanation in section 2 above for an explanation of our equal opportunities monitoring. | |
| Attending our premises for interview(s) | If you attend our premises, your details may be recorded in a visitor’s book on reception. CCTV systems may be in operation for the safety and security of our staff, visitors and property. Please refer to the signs located on and in our premises. |
The above information is mandatory for the application and recruitment process because of the nature of our business and our legal and regulatory responsibilities as referred to above. We recognise that the employment screening checks described above may be more extensive than you are used to. If you wish to discuss these checks in further detail or raise a specific concern, please call your Human Resources contact or email us at people@transunion.com.
4. HOW LONG IS THE PERSONAL DATA KEPT FOR?
To enable us to deal with any queries or issues that may arise from the job application process, we will generally retain your personal details in our records for a period of 12 months from the date that we formally notify you of our decision. Back-up copies of emails may be retained for longer subject to appropriate safeguards.
If your application is successful, to ensure business continuity we will transfer these records to your employee file upon commencement of employment.
5. WHAT IS OUR LEGAL BASIS FOR HANDLING PERSONAL DATA?
This section explains the basis on which we process your personal data.
Taking steps prior to entering a contract
We process data to the extent necessary to take steps at your request prior to entering into any contract of employment that may arise regarding your job application.
Legal obligations
We process data to the extent necessary to comply with our legal and regulatory obligations, both generally as a business and in relation to your application for employment. For example, this includes the use of data to comply with equal opportunities requirements and disability adjustments.
Legitimate interests
Data protection law in the UK and European Union allows the use of your personal data where necessary for legitimate purposes provided that this isn’t outweighed by the impact it has on you. The law calls this the “legitimate interests” condition for processing personal data.
The legitimate interests we are pursuing are:
- administering and managing the recruitment process;
- assessing and confirming an applicant’s suitability for employment;
- deciding to whom to offer a job;
- keeping records of this process to explain or justify our position in doing so.
With your consent
If you have signed up to receive job alerts through the careers pages of the www.transunion.co.uk website, we will send you alerts on the basis of your consent. You can unsubscribe from receipt of these alerts at any time.
6. WHO DO WE SHARE THE PERSONAL DATA WITH?
Our group companies
When we need to do so, we may share your personal data among the members of TransUnion Europe and within the wider TransUnion group. When we do this, use of the data by those companies is governed by this privacy notice. A list of relevant European companies is set out below although the list may change from time to time.
| Group company | Registered office and main address |
|---|---|
| TransUnion Information Group Limited (company no. 4968328) | One Park Lane, Leeds, West Yorkshire LS3 1EP |
| TransUnion International UK Limited (company no. 3961870) | |
| Callcredit Marketing Limited (company no. 2733070) | |
| Iovation Limited (company no. 09906028) | |
| Argus Information and Advisory Services Limited (company no. 06445823) | |
| Trustev Limited (company no. 516425) | Cork Airport Business Park, Building 2100, Rathmacullig West Cork, Co. Cork, Cork, Ireland |
| TransUnion International Spain SLU | Avenida de la Industria, 18, 28760 Madrid, Spain |
| Soluciones Confirma ASNEnF-SIGNE, S.L. | |
| Confirma Sistemas de Información, S.L. |
We may also share your personal data with other companies within the wider TransUnion group as necessary. This includes:
- TransUnion LLC, 555 West Adams Street, Chicago, Illinois 60661
- TransUnion Global Technology Centre LLP, 9th Floor, Block 2,DLF IT/ITES Special Economic Zone Shivaji Gardens, Moonlight Stop, Manapakkam Saidapet Tamil Nadu 600089
- TransUnion Global Capability Centre Africa (Pty) Ltd, G floor, 9 & 10 floor,11 Alice Lane, Sandton, 2196, Gauteng, Johannesburg, South Africa 2197
- TransUnion Global Capability Center Costa Rica Limitada, San Jose-Escazu San Rafael, Trejos Montealegre, De Escazu Village, Three Hundred Meters to the West, Banco General Building, Sixth Floor
The wider TransUnion group also includes multiple other companies in various countries around the world. Details are available on the “About us” pages at https://www.transunion.com
Service providers
We may provide your information to third parties who help us use it for the purposes described in section 2. For example, third parties may:
- host our database of personal data, including our HR and recruitment management systems;
- broadcast emails and SMS messages.
These service providers will not be allowed to use your information for their own purposes or on behalf of other organisations, unless you agree otherwise.
Business transfers
If we are selling our business to a third party, or go through a corporate reorganisation, we will need to provide human resources records (including recruitment records) to the prospective purchasers and their professional advisers, as part of their enquiries. The records will be transferred in full when a transfer of the business undertaking is about to take place.
7. WHERE IS THE PERSONAL DATA STORED AND SENT?
Within the UK and the European Union
Personal data may be accessed from various locations in the UK and European Union, such as our regional headquarters at One Park Lane, Leeds, West Yorkshire LS3 1EP. In these cases, the use of the information in those locations is protected by European data protection standards.
Elsewhere
We also send information elsewhere in the world. For example:
- We will share data with other members of the wider TransUnion group. For example, our group company TransUnion LLC, which is based in the US, holds a global record of workers in the TransUnion group. Additionally, TransUnion’s HR, IT and security support functions are based around the world and may have access to data from any of the group’s overseas offices.
- Some of our service providers, for example our HR and recruitment management system providers, and some of our third party IT and network security providers, are overseas and will need to process personal data to provide the services.
- We may use cloud-based technology or a data centre or backup facility overseas, and people in other countries may also need to access data for purposes such as technical support or system development and testing.
While the United Kingdom and countries within the European Union all ensure a high standard of data protection law, some parts of the world may not provide the same level of legal protection in relation to personal data. As a result, when we do send personal data overseas, we will make sure that suitable safeguards are in place to protect the information. For example, these safeguards might include:
- Putting in place a contract with the recipient containing terms which have been approved by the relevant authorities as providing a suitable level of protection.
- Sending the information to an organisation which is a member of a scheme or which has been approved by the authorities as providing a suitable level of protection. One example is the Data Privacy Framework that has been agreed between the UK, European and US authorities.
If your information has been sent overseas like this, you can obtain further information about the safeguards used by contacting us using the details set out in section 1 above.
8. IS THE PERSONAL DATA USED TO MAKE AUTOMATED DECISIONS ABOUT YOU OR TO PROFILE YOU?
We perform the following automated decision-making and profiling activities using your personal data. When we refer to profiling, we mean using personal data to make predictions about you, or to categorise you into particular groups.
- Identity verification: As explained in section 2 above, we will use the information you provide with your application to help us to verify your identity. We do this by checking the information you give us against databases such as the electoral register and your credit file. If we cannot verify your identity we will ask for details of your previous addresses and additional documentary address verification.
- Personality profiles and aptitude testing: To provide an independent measure of your aptitude and personality, you may be asked to undertake an assessment exercise as part of the job application process. We do this using specialist third party testing solutions.
The above activities do not involve automated decisions in that we do not rely on any one, or any combination of these, as the sole basis for making a recruitment decision about you. They form only part of an overall assessment made by our recruitment team. Recruitment decisions will also take account of any representations you may make if you are unhappy about the outcome of these profiling activities on your application, or any clarifying information we may ask you for in response to the outcomes.
9. WHAT ARE YOUR RIGHTS?
You have several different rights in relation to the personal data that we hold about you. These are briefly described below. To enquire about exercising these rights, please use the contact details set out in section 1.
- Access: You have a right to find out what personal data we hold about you, and certain other information such as how we are using it.
- Withdrawal of consent: Where we rely on your consent to process your personal data (see section 5 above) you have the right to withdraw that consent at any time.
- Rectification: If the information that we hold about you is inaccurate or out of date, you have a right to ask us to correct it.
- Objection to legitimate interests: If you disagree with us relying on the legitimate interests legal basis for using your personal data (see section 5 above), you can object to us doing so. We will then reassess the extent to which we can continue to use the data in light of your particular circumstances.
- Erasure: In certain circumstances you can ask us to delete your personal data from our systems. However, this usually won’t apply to all of your data because we might have good reason for needing to keep some of it.
- Restriction: In some circumstances you can ask us to restrict the ways in which we use your personal data.
- Portability: You have the right to receive some limited kinds of information in a portable format.
10. WHO CAN YOU COMPLAIN TO IF YOU ARE UNHAPPY ABOUT THE USE OF YOUR PERSONAL DATA?
If you are not happy with the way we use or handle your personal data you should make contact so that we can investigate your concerns. Please contact us by sending an email to ukrecruitment@transunion.com.
You should also use this email address if you want to exercise any of your personal data rights referred to in section 9 above in relation to the job application activities referred to in this privacy notice.
You can also contact our Data Protection Officer at ukdpo@transunion.com.
You also have the right to lodge a complaint with the data protection authorities. In the UK, this is the Information Commissioner’s Office (ICO), and you can contact them online through the ICO’s website at www.ico.org.uk, by telephone on 0303 123 1113, or by writing to them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF. Contact details for EU data protection authorities are available at https://edpb.europa.eu/about-edpb/about-edpb/members_en