Recruitment Privacy Policy​

Contents
Your privacy is important to us
Who does this ‘Privacy Notice’ apply to?
Why we need personal information 
What personal information we need 
Sensitive information
The legal basis by which we process your personal data
Sharing personal data
Transfers outside of the EEA 
Data security 
Storage and destruction 
Future changes 
Your rights 
Contact details 

This privacy notice is for information only and you do not need to take any action. 

Your privacy is important to us

Brady Technologies and its subsidiaries and affiliates (“Brady”, “us” or “we”), understand that your privacy is important to you. Brady may process your personal data in our capacity as data controllers. We are committed to respecting your privacy and protecting your personal data, which is information that is capable of identifying you as an individual person. This Recruitment Privacy Notice (“Privacy Notice”) describes how we handle and protect your personal data in connection with Brady’s recruiting process and it sets out what rights you have in relation to it.

We will process your personal data in accordance with this Privacy Notice, unless such processing conflicts with the requirements of applicable law, in which case, applicable law will prevail.

Who does this ‘Privacy Notice’ apply to?

This Privacy Notice only applies to the personal data of job applicants and potential candidates for employment on a permanent or contract basis. Brady may also collect and process your personal data should we engage in due diligence related to a potential corporate acquisition of your current employer (e.g. if you are part of the senior leadership team of a target company). 

Why we need personal information 

We collect and use your personal data for legitimate human resources and business management reasons including:

• identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
• recordkeeping in relation to recruiting and hiring;
• ensuring compliance with legal requirements, including diversity and inclusion requirements and practices;
• ensuring compliance with contractual obligations, such as recruitment agents terms of business
• conducting criminal history checks as permitted by applicable law;
• protecting our legal rights to the extent authorized or permitted by law; or
• emergency situations where the health or safety of one or more individuals may be endangered.

We may also analyse your personal data or aggregated/pseudonymized data to improve our recruitment and hiring process and augment our ability to attract successful candidates.

If you fail to provide the information we need when requested, we will not be able to process your application successfully.

Whilst we may use data analytics to help us review large quantities of candidate and application data that we receive, the automated results are always considered in tandem with, and not in lieu of, human judgement and evaluation of individual candidates. We will not make decisions about your application based solely on automated decision-making.

What personal information we need

As used in this Privacy Notice, “personal data” means information that identifies job applicants and potential candidates for employment with us, either submitted as part of the online application and/or through alternative channels (e.g., via professional recruiting firms, heading hunting, or referrals).

We usually collect personal data directly from you when you apply for a role with us, such as  information you provided in your application form, CV and covering letter as well as your name, address, contact information, work rights, work and educational history, achievements, and test results, as well as any information that you provided during your interview or information that you have provided during the recruitment process. We collect similar personal data about you from third parties, such as professional recruitment agencies, your references, prior employers, Brady employees with whom you have interviewed, and employment background check providers, to the extent this is required for the role and permitted by applicable law. We may also collect personal data about you online to the extent that you have made this information publicly available. For example, we may find your profile on professional social media websites (such as LinkedIn) and contact you about suitable roles.

Brady will only collect and use information that is relevant to the recruitment process.  
If your application proceeds to shortlisting and/or offer stage, we will also be obtaining information from your referees.

Further information that may be collected during the recruitment process are interview notes and test results, pre-employment vetting, and health checks for fitness to work (if required for the role). 

If your application is successful and we are in a position to make a job offer, we will need additional information from you. 

We will tell you what we need at point and will send you a separate privacy notice explaining why we need it.

Sensitive information

Sensitive personal data is a subset of personal data and includes ethnicity, health, trade union membership, sexual orientation, as well as other categories as prescribed by law.

We may seek to obtain such data about a candidate where permitted to do so by applicable laws (e.g. equal opportunity monitoring).

We will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview. 
• We may require you to complete a health check or questionnaire on your health for the purpose of ascertaining your fitness to work (if required for the role). 
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.  This information will not be available to anyone involved in the selection process and will not be published except a part of a set of anonymised statistics.
• Information relating to nationality will be used for right to work checks.
• We do not envisage that we will process information about criminal convictions. If we do we will notify you of the specific purpose.

The legal basis by which we process your personal data

Our processing of your personal data for the purposes mentioned above is based: 

• in part, on our legitimate interest in evaluating your application to manage our relationship with you and to ensure that we recruit the appropriate employees, and to evaluate and maintain the efficacy of our recruiting process more generally;
• in part, on our need to perform contractual and precontractual measures in respect of our relationship with you;
• in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations;
  
  

Sharing personal data
Your personal data will be accessed by, the line manager/interviewers for the role, or collaborators in the hiring process such as members of the management team with an interest in the role, individuals performing administrative functions such as the People Team as well as IT personnel within Brady who may also have a limited access to your personal data to perform their jobs. 

We will only share your personal data with the following third parties for the purposes of processing your application: Applicant Tracking System provider, aptitude testing software provider (if applicable), previous employer and/or references and other Brady Legal Entities (as required), recruitment agencies in order to maintain compliance with candidate ownership terms between the agency and the Brady.

All our third-party service providers and other entities 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.

Transfers outside of the UK/EEA
As the Group operates internationally and with a global People function, your personal information may be processed by another entity within the Group.
Your personal data may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within the Brady Group.
We have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by Brady subsidiaries and affiliates within the Brady Group, including the transfer of your personal data to countries other than the one in which you reside.
Transfers outside the United Kingdom (UK) and/or the European Economic Area (EEA) will only take place if one of the following applies:

• The country receiving the data is considered by the UK / EU to provide an adequate level of data protection;
• The organisation receiving the data is covered by an arrangement recognised by the UK/EU as providing adequate standard of data protection;
• The transfer is governed by approved contractual clauses;
• The transfer has your consent
• The transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract; or
• The transfer is necessary for the performance of a contract with another person, which is in your interest.
• In addition, we may disclose or transfer your personal data in the event of a re-organisation, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
  

Data security
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. 

Storage and destruction
If you accept an offer of employment from us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific retention requirements. 
If we do not employ you, we will nevertheless continue to retain and use your personal data for a period six months (from the date the role closes). This is so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information.
In the event that your application is put forward by a recruitment agency we will retain a record of this to ensure compliance with candidate ownership terms between the agency and the Brady. After expiration of the relevant contractual terms will we securely destroy your personal information.
We may also choose to retain your application form, CV (including those sent speculatively) interview notes and relevant information gained during the application process; the legitimate basis for this being to consider your suitability for future vacancies. If we choose to use your data for this alternative purpose we will contact you within 1 month of the role closing to notify you. If you consent to this we will retain your personal data for up to 18 months from the date the role closes. You have the right to object to this processing. 
If we do not choose to retain your application (including those sent speculatively), we will securely destroy your personal information.

Future changes
While the content of this privacy notice is accurate at the date of issue, the Company may need to make changes in the future.  You will be notified of any relevant changes.  

By submitting your personal data to us, you acknowledge that:

• You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein. 
• Your personal data may be transferred and processed worldwide, including countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice. 
• You are not required to provide any requested information to us but failing to do so may result in not being able to continue your candidacy for the job for which you have applied. 
• All of your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment. 
• This Privacy Notice does not form part of any contract of employment offered to candidates hired by Brady.

Your rights
You have the right to access the personal information that we hold about you.  You can also ask us to correct any errors and, in certain circumstances, you can request that the use of your personal information is restricted.  Where the processing is taking place in pursuit of our legitimate interests, you also have the right to object to that processing or request that your personal information is erased.  Please contact us in relation to any such requests (contact details below).  
If you would like further information about your rights, you can look at the website of the Information Commissioners Office (www.ico.org.uk) or you can contact the Company (contact details below).  
If you have any issue in relation to the Company’s handling of your personal information, please contact us (contact details below).  At any time, you also have a right to lodge a complaint with the Information Commissioner’s Office at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF Tel: 0303 1231113 or 01625 545700
Fax: 01625 524510

Email: casework@ico.org.uk

Contact details
If you have any questions about this privacy notice, please contact Data Privacy Manager at 
data.protection@bradytechnologies.com.

Or 

You can contact us at:
Centennium House
100 Lower Thames Street
London, EC3R 6DL
UK

Our Norway subsidiary acts as our EU Representative. You may contact us at our Norway office address:
Dronning Eufemias gt 16
0191 – Oslo
Norway

Revision History Version: V4
Authorised By: CFO
Last Reviewed: March 2022
Reviewed by: People
Next Review due: March 2023