Ford Motor Company Limited and FCE Bank PLC Limited
Data Protection - Privacy Notice - Recruitment
We will collect, hold and process personal data relating to you if you apply for a position with us. We will use the information you give us in connection with recruitment for the role for which you have applied. If we decide to offer you employment, information relating to your application will be used in connection with that offer and your employment with us.
Introduction
1. This Privacy Notice explains how and why we process personal information (which we call ”personal data”) about job applicants. In this Notice, we use the word “you” to refer to anyone within the scope of this Notice. It applies when you apply for a position at Ford Motor Company Ltd and/or FCE Bank PLC and therefore references to ‘we’ and ‘Ford’ apply to the relevant entity or entities to whom you are applying.
Where does the personal data come from and what kind of data is processed?
2. In recruiting, most personal data comes from you either directly or from our recruitment agencies who process applications on our behalf. This may be in your CV or an application form. It is likely to relate to your contact details and experience, skills and qualifications. We also make records of our assessment and evaluation of your application, of decisions on short-listing, of interviews, and decisions on whether or not to offer you a job. If you take part in assessment tests, we will keep a record of those.
3. If we decide to offer you a job, we will require information from you to ensure that you have the right to work in the UK. We may also receive information from third parties such as your referees, recruitment agents and, if we carry out background checks, from background check providers.
4. We may receive and process information regarding your health. This may be to consider reasonable adjustments either to the recruitment process or the job applied for. We may also, in some cases, require you to undertake a pre-employment medical examination. Personal health data may come from you or third parties such as our Occupational Health Department or other medical experts.
5. If you attend for interview or assessment, we may have a CCTV record of you at our premises.
6. We also carry out diversity monitoring. If you opt to provide information on your nationality, racial or ethnic origin, sexual orientation, religion or belief, disability or age, this will only be used for monitoring and reporting. Data in reports will be aggregated and will not identify individuals.
7. We collect and may disclose statistical information gathered in relation to our recruitment activities for internal reporting purposes and to improve applicant experience. However, we never disclose information that identifies any individual for such purposes.
8. You should be aware that 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. 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.
Who sees my personal data?
9. Only those who have a legitimate need to access your personal information will be able to do so. Access to personal data relating to your application is usually restricted to relevant managers and HR officers and recruitment staff (including third party recruitment agency staff and background check providers) other than in exceptional circumstances in line with the purposes set out in this Notice e.g. if required by law.
10. Where personal data is disclosed to third parties, it will be on the basis that this is consistent with our grounds for processing and doing so is lawful and fair to you. It will be used only in connection with your recruitment and all our third party providers are required to take appropriate security measures to protect personal information in line with our policies and we do not permit them to use your personal data other than for our specified reasons. We may also transfer data to law enforcement agencies, courts, regulators and government authorities if required or appropriate to do so.
11. In some cases personal data may be shared with other entities within the Ford group such as FCE Bank PLC. This would be in line with the purposes and legal grounds for processing set out in this Notice. For example where, in relation to a particular recruitment campaign, there is a requirement not to have applied to a different Ford entity within the previous 12 months the relevant entities may share lists of recent applicants to confirm compliance with this requirement.
Purposes of and legal bases of processing
12. We set out below the purposes for which we process data relating to job applicants and the legal basis for processing that data. We highlight in red and underline where the purpose may include the processing of sensitive personal data such as health data or data revealing racial or ethnic origin and the legal basis for processing in such cases.
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Purpose
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Legal basis for processing
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Considering and assessing job applications against the requirements of the job including short-listing and interviewing
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Legitimate interests
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Deciding whether to offer a job and offering a job
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Legitimate interests
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Making adjustments if appropriate in relation to a disability and, where relevant, undertaking pre-employment medical examinations
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Legal necessity
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Monitoring and promotion of diversity and equal opportunities
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Legitimate interests, legal obligation and legal necessity and public interest
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Ensuring physical security of our premises including by use of CCTV
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Legitimate interests
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Disputes and legal proceedings
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Legitimate interests and legal obligation
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Compliance and regulatory including undertaking checks such as establishing if applicant has right to work in UK
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Legitimate interests and legal obligation
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There are also special protections in relation criminal convictions and offences. We will only process data in relation to criminal convictions in limited circumstances and where it is lawful for us to do so.
Automated decision-making
13. We use automated decision making in some of our recruitment exercises as we consider it necessary for entering into the employment contracts envisaged by the recruitment exercise as a result of the high volume of applications we receive. This automated decision making relates to the automatic rejection of candidates at the application stage if, for example, you do not meet our degree requirements or are unable to start on our specified start date. Further, in some cases we use online numerical/reasoning tests and, if you do not meet our required pass mark, will result in you not progressing further. In relation to this automated decision making you have the right to obtain human intervention, to express your point of view and to obtain an explanation and contest the decision. If you wish to exercise these rights then please contact the Recruitment Team (see below).
Transfers of personal data outside the EEA
14. In connection with our business and for employment, administrative, management and legal purposes, when processing data in line with this Notice we may transfer your personal data outside the EEA (including to the USA and India). If we transfer your personal information outside the EEA we will put in place appropriate safeguards in accordance with our legal obligations to ensure that your personal data is adequately protected irrespective of the country to which it is transferred. These safeguards may include obtaining contractual assurances from any third party given access to your personal data that your personal data will be protected by standards which are equivalent to those that protect your personal data when it is in the EEA. If you would like to know more about how we protect your personal information when it is transferred outside the EEA, please contact our Recruitment Team on the following email: careeruk@ford.com.
How long do we keep your data?
15. We do not keep your personal data for longer than is necessary for our purposes. In general, we will keep the personal data stored in for the duration of the recruitment campaign and for a reasonable period thereafter on the basis it may be relevant to our business either as a record or in the event of a legal claim. Our current assessment of a reasonable period is 6 months – unless you are recruited. Other data may be retained for a shorter period (e.g. CCTV footage).
16. If you are employed by us, any relevant personal data collected in connection with your application will form part of your personnel record. We will keep it in line with our data retention policies.
Access to your personal data and other rights
17. If you wish to see any personal data relating to you, we would recommend that you contact the Recruitment Team (careeruk@ford.com).
18. You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with certain information about it, including:
- Giving you a description and copy of the personal data; and
- Telling you why we are processing it.
19. If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
20. As well as your subject access right, you have other legal rights which, in certain circumstances allow you to have your personal data rectified or erased, to object to its processing or to have its processing restricted. You may also be able to request the transfer of certain data to another party. If you wish to know more about these rights or wish to exercise them please contact our Data Protection Officer (dpeurope@ford.com).
Contacting us
21. If you have any queries regarding this notice, then in the first instance we recommend you contact the Recruitment Team (careeruk@ford.com).
22. In processing your personal data, we act as a data controller. Our contact details are as follows:
- Ford Motor Company Ltd - The Company Secretary, Ford Motor Company Ltd, Dunton Campus, Arterial Road, Laindon, Essex, SS15 6EE, England.
- FCE Bank PLC - The Company Secretary, FCE Bank PLC Dunton Campus, Arterial Road, Laindon, Essex, SS15 6EE, England.
23. Also, we have appointed a Data Protection Officer (jointly for Ford Motor Company Ltd and FCE Bank PLC) whose role includes informing and advising us and those who are involved in processing data of their obligations under data protection laws. The contact details of the data protection officer are dpeurope@ford.com.
Complaints
24. If you have any complaints relating to our processing of your personal data, you should raise these with the Recruitment Team (careeruk@ford.com) in the first instance or with our Data Protection Officer (dpeurope@ford.com). You may also raise complaints with the Information Commissioner who is the statutory regulator. For further information see: https://ico.org.uk or you can contact the Information Commissioner’s Office (ICO) helpline on 0303123113.
Status of this Privacy Notice
This Notice does not form part of any contract of employment and does not create contractual rights or obligations. It may be amended by us at any time.
