1. General
Moto Hospitality Limited is a “data controller” as we are responsible for deciding how we hold and use personal information about you.
The information you provide during the application process will be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements where necessary.
2. Types of Personal Information and Reasons for Collection
The types of personal information we will initially collect during the application process include the following:
- name, address, date of birth, gender, nationality; contact details (phone number and email);
- your C.V., information on your application form, such as previous experience, and qualifications;
- special categories of personal information such as: your ethnic origin or whether you regard yourself as having a disability, for optional equal opportunities monitoring and in relation to any adjustments required to the recruitment process, which would assist you if you are invited to interview;
- we may also ask you about criminal convictions where this is a requirement for the role (see information about criminal convictions).
If you progress to the interview stage, we may collect the following additional information:
- interview notes;
- copies of certificates of professional and academic qualifications; ,
- “right to work” documentation (e.g. marriage certificate, passport etc).
If you are offered a job, we may collect the following additional information, depending upon the role you are offered and/or the benefits offered in connection with your role:
- References, e.g. from current/former employers;
- DVLA forms; and/or Disclosure and Barring Service (DBS) forms and information required to process a DBS application, if you are required to hold an alcohol licence;
- medical information in relation to any disability or illness you may have, in order to make adjustments, carry out risk assessments and/or put in place support plans.
The reasons we collect and process this information during the recruitment process are to:
- to identify you and ensure you are legally entitled to work in the UK, and so that we can comply with our legal requirements;
- to assess your suitability for the role;
- to contact you about your application, to progress your application and to make decisions about it;
- in relation to the special categories of personal information, for the reasons stated above.
- There may also be additional valid reasons for which we are permitted or required to process your data.
If you do not provide information when requested we may not be able to progress your application.
3. Collection of Information
We mainly collect your personal information directly from you, although in some circumstances it will be provided by third parties, for example from:
- referees you have given;
- government agencies (e.g. the Home Office, for right to work checks; the DBS for criminal record checks; the DVLA for driving entitlement information.
We will inform you if we intend to collect information from a third party. In some cases we will only obtain such information where you have given your consent.
4. Basis for Collecting and Processing
The basis on which Moto is permitted to collect and process your personal information in connection with your recruitment, will generally include one or more of the following reasons:
It is in our legitimate interests to collect and process this information, in order to decide if you are eligible and suitable to work for Moto in a particular role;
We need this information to comply with legal requirements; and/or
In relation to certain information, where you have given your consent.
Where your personal information is in a special category, we will only collect and process it for one or more of the following reasons:
- Where you have given your explicit written consent;
- Where we need to carry out our obligations and/or exercise our rights in relation to employment and other laws;
- Where it is needed in the public interest, e.g. for equal opportunities monitoring;
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards; and/or
- Where it is necessary in relation to legal claims.
In limited circumstances other legally permitted reasons may also apply for processing personal information, including where it is in a special category.
5. Information about Criminal Convictions
Where it is a requirement for the role, we will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory).
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
We may only process Personal Data relating to criminal convictions where the law allows this. This will usually be where such processing is necessary to carry out our obligations as employers, and provided that we do so in accordance with our Data Protection Policy. We might also use Personal Data relating to criminal convictions where it is necessary in relation to legal claims or where you have made the information public.
6. Consent
Please note that if your consent is requested in relation to processing personal information, you will not be required to give your consent and if you have given consent, you will be entitled to withdraw it. However, your consent is not required in all circumstances – including where personal data is collected for the reasons given above.
7. Automated Decision-Making
Final recruitment decisions are made by Moto’s hiring managers and members of our recruitment team. All of the information gathered during the application process is taken into account.
In relation to the pre-application questions that we ask before you can progress to your full application, we may make very limited automated decisions about you in relation to your eligibility and/or suitability for the role. We ask these questions in order to help us decide if we will enter into a contract with you. In addition, in completing the pre-application questions, you are giving us your consent for these automated decisions to be taken. However, if you wish to challenge a decision made in relation to these pre-application questions or if you wish to give us any additional information that you think might be relevant, please contact us on: careers@moto-way.co.uk or on 01525 878 454.
8. Who May Receive Your Personal Information
Where you apply on-line for a position at Moto, your application details will be processed by a third party data processor on our behalf and Moto will ensure that we have an appropriate contract in place to protect your personal information. We don’t allow our third party data processors to use your information for their own purposes – they must act only on our instructions and are subject to a duty of confidentiality.
Our human resources teams (as well as other relevant Moto employees, for example in the IT and legal departments and/or the site management teams) will also have access to the information you supply during the application process.
In addition, the information you provide in relation to your application may be shared where required with our auditors and external consultants and advisors e.g. legal advisors; and/or regulatory and/or other authorities and law enforcement agencies.
9. Data Security
We have put in place appropriate security measures to protect your personal data. These controls include that only those with a need to access your personal information are able to do so.
10. How Long Your Data Will Be Stored For
Where you apply via our on-line recruitment portal, our third party data processor will retain your application details, on our behalf, and on your behalf, as follows
Your candidate profile and associated personal data will be archived when the following conditions have been met:
- All the vacancies for which you have applied have been inactive for 6 months and the vacancies have themselves been archived;
- You have NOT opted in to having your data retained as part of a “talent pool”;
- You have not logged in to your profile for 6 months;
- You have not updated your candidate profile for 6 months.
Once archived, your personal data will no longer be visible in the Moto admin / recruiter portal. After a further 1 month, the data will be deleted from our on-line recruitment provider’s systems.
Where you have not been successful in your application we may offer you the chance to retain your personal information in the “talent pool” on our systems, in case a further job opportunity at Moto arises in future, which you would like us to consider you for. Where you consent to your details being kept in the “talent pool”, these details will be retained for a further 12 months from the date of your completed application. If you wish to withdraw your consent and be removed from the talent pool, please contact us on careers@moto-way.co.uk.
Where you have been interviewed but your application has been unsuccessful, your interview notes will be retained, in a secure file, at the site at which you were interviewed, for 12 months from the date of your interview.
Where your application has been successful your personal information from the application process will be retained, as part of your employee file. Your employee file will generally be retained for the duration of your employment plus 6 years following the end of your employment, except as otherwise set out in Moto’s Privacy Notice for Employees and Workers, which will be available to you when you start work at Moto.
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.
11. Your Rights In Relation To Your Personal Information
In certain circumstances, you have the following rights to:
- request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
- request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it;
- 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 may then request erasure);
- 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;
- request the transfer of your personal information to another party;
- withdraw consent where you have provided consent to processing your personal information;
- to lodge a complaint with the Information Commissioner’s Office. Details may be found on their website www.ico.org.uk
If you want to exercise any of these rights please contact the Moto HR Department, in writing on careers@moto-way.co.uk or by phone on 01525 878 454.
Please note that Moto does not need to comply with all your requests but if we do not agree to, we will inform you of the reason why.