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Wave Multi Academy Trust​ Privacy Statement

The following explains how we Wave Multi Academy Trust (Controllers) intend to use the information you provide in your application, along with your rights, our reasons for requesting it and who will have access to it.

As defined by the General Data Protection Regulation (GDPR) Wave Multi Academy Trust is the Data Controller and ultimately responsible for ensuring the data you provide is kept secure, processed correctly and that you understand your legal rights in relation to the data you provide.

The recruitment software we use via this website is supplied by IRIS Software Group Limited and they are defined as a Data Processor under the GDPR. They will only process your data in accordance with our instructions.

IRIS can be contacted at: 4th Floor Heathrow Approach, 470 London Road, Slough, England, SL3 8QY

For Data Protection enquiries, please contact the Help Desk at support@networxrecruitment.com

What information do we collect from you?

We collect a range of information about you, this includes:

• Your name, address and contact details, including email address and telephone number.
• Relevant documentation which confirms your identification and proof of address.
• Details of your education, qualifications and training, including membership of professional bodies.
• Information about your current level of remuneration, including benefit entitlements.
• Information about your continuous service in Local Government Employment.
• Details of your skills, experience, current employment and previous employment.
• Details of relationships you may have with current employees within the Trust.
• Relevant information to enable us to undertake safer recruitment in education checks, including details of referees.
• Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process.
• Information about your entitlement to work in the UK.
• Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.
• Information on any incidents or issues that may have been identified in online checks of publicly available information.

Why do we collect this information and who do we share it with?

We use job applicant data to:

• Take steps at your request prior to entering into a contract with you
• Enter into a contract with you
• Ensure that we are complying with our legal obligations
• If we need to perform an official task in the public interest

Under the UK General Data Protection Regulation (UK GDPR), the legal basis / bases we rely on for processing personal information for general purposes are: (6a) Consent; (6c) A Legal obligation; (6d) A duty to safeguard pupils; (6e) Public task. The lawful bases for processing personal data are set out in Article 6 of the UK General Data Protection Regulation.

Special Categories of data are set out in Article 9 of the UK General Data Protection Regulation. Wave Trust will work within the conditions of GDPR - Article 9 of the UK GDPR:

will work within the conditions of GDPR - Article 9 of the UK GDPR: (9.2a) explicit consent; (9.2b) processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law; (9.2c) where processing is necessary to protect the vital interests of the data subject or of another natural person; (9.2f) for the establishment, exercise or defence of legal claims; (9.2g) reasons of substantial public interest; (9.2j) for archiving purposes in the public interest.

We process criminal offence data under Article 10 of the UK GDPR.

Our Data Protection Policy highlights the conditions for processing in Schedule 1 of the Data Protection Act 2018 that we process Special Category and Criminal Offence data under.

We collect this information in a variety of ways. For example, data might be contained in application forms or CVs, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

We 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.

We will also carry out an online search about you for information that is publicly available online. This will include social media accounts you may hold. This will only be carried out on shortlisted candidates and before interview. This processing of data will be conducted under the legal basis of Article 6(e) public task in line with the guidance laid out in Keeping Children Safe in Education (KCSIE). Any data collected during this search will be retained in line with our retention schedule which is available on request.

Who we share job application information with

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the academy staff who carry out HR activities, the central HR team and 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. We will use our secure HR Management Information System.

To meet our duties under Keeping Children Safe in Education, we are required to obtain references from your former employers as part of the interview process. We will not share your data with third parties for this purpose without your consent.

The organisation will share data with third parties with employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

We will store your application data for 6 months after the vacancy has closed. After this period, it will be fully anonymised.

How can I access the information you hold about me? Your rights

The UK-GDPR gives you certain rights about how your information is collected and used. To make a request for your personal information, contact enquiries@waveedu.org.

You also have the following rights:

• the right to be informed about the collection and use of your personal data – this is called ’right to be informed’.
• the right to ask us for copies of personal information we have about you – this is called ’right of access’, this is also known as a subject access request, data subject access request or right of access request.
• the right to ask us to change any information you think is not accurate or complete – this is called ‘right to rectification’.
• the right to ask us to delete your personal information – this is called ‘right to erasure’
• the right to ask us to stop using your information – this is called ‘right to restriction of processing’.
• the ‘right to object to processing’ of your information, in certain circumstances
• rights in relation to automated decision making and profiling.
• the right to withdraw consent at any time (where relevant).
• the right to complain to the Information Commissioner if you feel we have not used your information in the right way.

There are legitimate reasons why we may refuse your information rights request, which depends on why we are processing it. For example, some rights will not apply:

• right to erasure does not apply when the lawful basis for processing is legal obligation or public task.
• right to portability does not apply when the lawful basis for processing is legal obligation, vital interests, public task or legitimate interests.
• right to object does not apply when the lawful basis for processing is contract, legal obligation or vital interests. And if the lawful basis is consent, you don’t haven’t the right to object, but you have the right to withdraw consent.

Within your candidate account, you can also use the Download Data feature to generate an XML file of the current data we hold on you that you have provided and/or have access to within the account.

Where we process your personal data based on your consent, you have the right to withdraw that consent at any time.

To request the withdrawal of your consent, please contact the Executive Assistant at  enquiries@waveedu.org or 01209 211525. We will respond to your request promptly and ensure that your data is no longer processed on the basis of consent, unless another lawful basis applies.

If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office at raise a concern with ICO

Alternatively, you can contact our Data Protection Officer which is SchoolPro TLC Ltd via DPO@schoolpro.uk.

What if You Do Not Provide Personal Data?

You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we 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.

Right to Lodge a Complaint

Under Section 164A of the Data Protection Act 2018, you have a statutory right to complain if you believe your personal data has been handled inappropriately.

If you wish to raise a concern about how we process your personal data, please contact us directly at complaints@waveedu.org. We will acknowledge your complaint within 30 days of receipt and take appropriate steps to investigate and respond without undue delay.

If you are not satisfied with our response, you may escalate your complaint to the Information Commission at: Information Commissioner's Office

Wave Multi Academy Trust can exercise the right to update this policy as and when required.