Data Controller: Accord Housing Association Ltd, 178 Birmingham Road,
West Bromwich, West Midlands B70 6QG.
Does this Notice Apply to You?
This privacy notice applies to all applicants that are not currently staff members
of Accord Housing Association. If you are applying for a promotion or another job
in the organisation and are already employed by Accord Housing Association, please
refer to the privacy notice for staff.
What is the Purpose of this Document?
Accord Housing Association Ltd is committed to protecting the privacy and security
of your personal information. This privacy notice describes how we collect and use
personal information about you during and after the application process, in accordance
with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018,
and any national laws, regulations and secondary legislation, as amended or updated
from time to time, in the United Kingdom, and any other territory which implements
Accord Housing Association Ltd will be your data controller. This means that we are
responsible for deciding how we hold and use personal information about you. We are
required under data protection legislation to notify you of the information contained
in this privacy notice.
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
Data Protection Principles
We will comply with data protection law. This says that the personal information we
hold about you must 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 only as long as necessary for the purposes we have told you about.
- Kept securely
How Your Personal Data May Be Used
Here at Accord Housing Association Ltd we take your privacy seriously. As part of Accord’s
recruitment process, we collect and process personal data relating to job applicants. We are
committed to being transparent about how we collect and use that data and to meeting our data
What Personal Data Does Accord Collect?
Personal data, or personal information, means any information about an individual
from which that person can be identified. It does not include data where the identity
has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher
level of protection.
Accord collects a range of personal data about you that is relevant to your
application. This includes:
- your name, address and contact details, including email address and
- date of birth;
- marital status and dependents;
- national insurance number;
- next of kin and emergency contact information;
- copy of driving licence;
- information included in a CV or cover letter or as part of the application
- details of your qualifications, skills, experience and employment history,
including any gaps in employment and referees and job titles, work history
and professional memberships;
- information about your current level of remuneration, including benefit
- Any cautions or convictions you have, including any pending criminal charges,
and your health and mental fitness for the post under Schedule 3 of the
Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.
- Whether you are related to an Accord Committee member, existing member
of staff, an Accord Contractor or an Accord tenant. (Schedule 1 information).
- whether or not you have a disability for which we need to make reasonable
adjustments during the recruitment process; and
- Information about your entitlement to work in the UK such as passports, visas
or national identity cards.
We may also collect, store and use the following “special categories” of more
sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation
and political opinions.
- Information about your health, including any medical condition, health and
- Information about criminal convictions and offences.
Accord may collect 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.
Accord may 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.
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).
Accord may use different web-based job application services in order to advertise
vacant roles and to obtain job applications. In some instances, Accord will be known
as the “Controller” of the personal data you provide, meaning that it is responsible for
what personal data is collected and how it is accessed, shared or deleted. Typically
this occurs when you apply directly for a role with Accord or via a web-based job
application service where your personal data is sent directly to us.
Accord also used job application services where it is the “Processor”. Typically this is
where you do not provide us with your personal data directly but via a job application
website. In this instance we will process the personal data in exactly the same
manner but we will have a Data Sharing Agreement with the third party who provides
the job application service. We will only enter into such an agreement where we can
guarantee that your personal data is accessed securely, is accessed only by those
who have a legitimate interest or lawful purpose to access it, and where the personal
data can be securely removed after a specific period of time.
Why Accord Collects Your Personal Data
We will only use your personal information where the law allows us to. Accord
needs to process personal data to take steps at your request prior to entering into a
contract with you. It may also need to process your data to enter into a contract with
In some cases, Accord needs to process personal 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.
We may also use your personal information in the following situations, which are
likely to be rare:
- Where we need to protect your interests (or someone else’s interests);
- Where it is needed in the public interest or for official purposes.
We need all the categories of information in the list above primarily to allow us to
enable us to comply with legal obligations.
- Making a decision about your recruitment or appointment.
- Determining the terms on which you work for us.
- Checking you are legally entitled to work in the work location in which you are
- Assessing qualifications for a particular job or task.
- Education, training and development requirements
- Dealing with legal disputes involving you, or other employees, workers and
- Ascertaining your fitness to work.
- Complying with health and safety obligations.
- To prevent fraud.
- Equal opportunities monitoring.
Some of the above grounds for processing will overlap and there may be several
grounds which justify our use of your personal information.
Accord 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 Accord to manage the recruitment process, assess and confirm a candidate's
suitability for employment and decide to whom to offer a job. Accord may also need
to process data from job applicants to respond to and defend against legal claims.
"Special categories" of particularly sensitive personal information require higher
levels of protection. We need to have further justification for collecting, storing and
using this type of personal information. We may process special categories of
personal information in the following circumstances:
- In limited circumstances, with your explicit written consent. If we need your
consent we will contact you separately about this.
- Where we need to carry out our legal obligations and in line with our Data
- Where it is needed in the public interest, such as for equal opportunities
monitoring or, and in line with our Data Protection policy and HR Equal
Opportunities and Diversity policy.
- Where it is needed to assess your working capacity on health grounds,
subject to appropriate confidentiality safeguards.
Less commonly, we may process this type of information where it is needed in
relation to legal claims or where it is needed 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.
We will use your particularly sensitive personal information in the following ways:
- We will use information about your physical or mental health, or disability
status, to ensure your health and safety in the workplace and to assess your
fitness to work, to provide appropriate workplace adjustments, to monitor and
manage sickness absence and to administer benefits.
- We will use information about your race or national or ethnic origin, religious,
philosophical or moral beliefs, or your sexual life or sexual orientation and
disability status, to ensure meaningful equal opportunity monitoring and
reporting and to comply with employment and other laws.
Accord may process special categories of data, such as information about ethnic
origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may
also collect information about whether or not applicants are disabled to make
reasonable adjustments for candidates who have a disability. Accord processes such
information to carry out its obligations and exercise specific rights in relation to
For some roles, Accord is obliged to seek information about criminal convictions and
offences. Where Accord seeks this information, it does so because it is necessary for
it to carry out its obligations and exercise specific rights in relation to employment.
Under The Childcare (Disqualification) Regulations 2009, section 75 of the Childcare
Act 2006, this may also include convictions or cautions of family members or any
lodgers living with you.
Accord will not use your data for any purpose other than the recruitment exercise for
which you have applied.
Do we need your Consent?
We do not need your consent if we use special categories of your personal
information in accordance with our written policy to carry out our legal obligations or
exercise specific rights in connection with your employment. In limited
circumstances, we may approach you for your written consent to allow us to process
certain particularly sensitive data. If we do so, we will provide you with full details of
the information that we would like and the reason we need it, so that you can
carefully consider whether you wish to consent. You should be aware that it is not a
condition of employment with us that you agree to any request for consent from us.
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
obligations and provided we do so in line with our Data Protection policy.
Less commonly, we may use information relating to criminal convictions where it is
necessary in relation to legal claims, where it is necessary 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.
We may hold information about criminal convictions.
We will only collect information about criminal convictions if it is appropriate given the
nature of the role applied for and where we are legally able to do so. Where
appropriate, we will collect information about criminal convictions as part of the
recruitment process or we may be notified of such information directly by you in the
course of the recruitment process. We will use information about criminal convictions
and offences as part of the assessment for initial hiring.
Who Has Access To Personal Data?
Your information may 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.
Accord will not share your data with third parties unless your application for
employment is successful and it makes you an offer of employment. Accord 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.
"Third parties" includes third-party service providers (including contractors and
designated agents) and other entities within our group.
All our third-party service providers and other entitled in the group are required to
take appropriate security measures 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.
Accord will not transfer your data outside the European Economic Area.
How does Accord Protect Personal Data?
Accord has internal policies and controls in place – such as an Information Security
Policy, a Data Protection Policy and a Data Retention Policy - 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.
We have put in place appropriate security measures to prevent your personal
information from being accidentally 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.
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.
For How Long Does Accord Keep Personal Data?
If your application for employment is unsuccessful, Accord will hold your data on file
for 24 months after the end of the relevant recruitment process. At the end of that
period, your personal data is deleted or destroyed.
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 personal data will be held will be
provided to you in a new privacy notice.
We will only retain your personal information for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any legal,
accounting, or reporting requirements. To determine the appropriate retention period
for personal data, we consider the amount, nature, and sensitivity of the personal
data, the potential risk of harm from unauthorised use or disclosure of your personal
data, the purposes for which we process your personal data and whether we can
achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can
no longer be associated with you, in which case we may use such information
without further notice to you. If you are unsuccessful in your application, we will
retain and securely destroy your personal information in accordance with our Data
As a Data Subject, you have a number of rights over the way in which Accord
processes your Personal Data.
If you would like to exercise any of the rights below, please contact Accord’s Data
Protection Officer (firstname.lastname@example.org) or write to us at Data Protection
Officer, Accord Housing Association Ltd, 178 Birmingham Road, West Bromwich
- You can request a copy of the Personal Data that we hold about you by using
one of the following options:
Completing a request online or via email will generally be a quicker process
than relying upon post. We will generally provide information electronically via
password-protected PDF so that it remains secure when sent.
- completing a Subject Access Request form (available from our website),
- emailing us, at email@example.com, or
- writing to us at: Subject Access Request, Accord Housing Association
Ltd, 178 Birmingham Road, West Bromwich B70 6QG.
- We want to make sure that your Personal Data is accurate and up to date. If
you believe that the information we hold is incorrect and needs to be updated,
please contact us and we will help to make sure that the information is
- You have a right for Personal Data to be forgotten as long as it is not essential
to the job application process. Contact us if you would like your Personal Data
to be deleted.
- You have a right to 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 particular 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.
- You have a right to 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
the reason for processing it.
- You have a right to request the transfer of your personal information to
- If you wish to raise a complaint on how we have handled your Personal Data,
you can contact us and we will investigate your query within 72 hours.
If you believe that Accord has not complied with your data protection rights, you can
complain to the Information Commissioners Office via the following web-site
You will not have to pay a fee to access your personal information (or to exercise
any of the other rights). However, we may charge a reasonable fee if your request
for access is clearly unfounded or excessive. Alternatively, we may refuse to comply
with the request in such circumstances.
We may need to request specific information from you to help us confirm your
identity and ensure your right to access the information (or to exercise any of your
other rights). This is another appropriate security measure to ensure that personal
information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the
collection, processing and transfer of your personal information for a specific
purpose, you have the right to withdraw your consent for that specific processing at
any time. Once we have received notification that you have withdrawn your consent,
we will no longer process your information for the purpose or purposes you originally
agreed to, unless we have another legitimate basis for doing so in law.
What If You Do Not Provide Personal Data?
You are under no statutory or contractual obligation to provide data to Accord during
the recruitment process. However, if you do not provide the information, Accord may
not be able to process your application properly or at all.
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
Accord may use any automated decision-making, from time to time, as part of the job application process.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide
you with a new privacy notice when we make any substantial updates. We may also
notify you in other ways from time to time about the processing of your personal