Policy Statement

This policy documents your privacy rights and how we gather, use and share personal data about you during the recruitment process, in accordance with the General Data Protection Regulation (EU) 2016/679, as well as other data protection and privacy laws and separate UK data protection law as may be updated or replaced from time to time. This Privacy Notice was last updated on 20 July 2023.

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 data about you, so that you are aware of how and why we are using such information. This notice shall not form part of any employment contract which you may enter into with us, and we reserve the right to amend this notice at any time.

Scope

This notice applies to all job applicants (including temporary staff, agency staff, subcontractors and interns) and to all recruitment activities undertaken by EAL, including those undertaken on behalf of third-party business partners.

As part of any recruitment process, EAL collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

EAL collects a range of information about you. This includes:

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.

The organisation collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

The organisation will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks from the UK and overseas. The organisation will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Storage and Recording

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Hard copy records will be kept securely in a lockable, non-portable container, and when a room containing records is left unattended, it should be locked.

Why Data is Processed

EAL needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.

In some cases, EAL needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.

EAL has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the
organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. EAL may also need to process data from job applicants to respond to and defend against legal claims.

EAL relies on legitimate interests as a reason for processing data and it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

EAL processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its legal
obligations and exercise specific rights in relation to employment.

Where the organisation processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal
opportunities monitoring purposes.

EAL is also obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its legal obligations and exercise specific rights in relation to employment and the issue of an airside pass.

If your application is unsuccessful, EAL will keep your personal data on file in case there are future employment opportunities for which you may be suited. The organisation will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Access

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks. Where EAL has undertaken recruitment activities on behalf of third-party business partners, EAL will also share your information with the organisation with a vacancy.

Your data may be transferred outside the European Economic Area (EEA) only to enable receipt of an Overseas Criminal Records Check. Data is transferred outside the EEA on the basis of individual country rules and guidelines.

EAL takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

Applicant Access

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• require the organisation to change incorrect or incomplete data;
• require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and
• ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation’s legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact our Data Protection Officer – dpo@edinburghairport.com.

If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.

Not Providing Data

You are under no statutory or contractual obligation to provide data to EAL during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

Retention and Destruction

If your application for employment is unsuccessful, the organisation will hold your data on file for 12 months after the last date you accessed your Candidate Profile. At the end of that period or once you withdraw your consent, your data is deleted or destroyed. You may at any time request that your data is held for longer than 12 months.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in the Employee Privacy Notice. Where EAL has undertaken recruitment activities on behalf of third-party business partners, please refer to their Employee Privacy Notice for details about how long your data will be retained for.

Automated Decision Making

EAL’s recruitment processes are not based solely on automated decision-making.

We do however use online testing when screening for X-ray competence for applicants joining the Security team. This screening is in the form of an online test. If this test is failed, your application for employment will be rejected.