Introduction
We are The Washing Machine Project (TWMP). We are a company registered in England and Wales with company number 12113634. Our registered office is at 92 Mansell Road, Greenford, UB6 9EL.
In this privacy notice, we will refer to ourselves as ‘we,’ ‘us’ or ‘our’.
We take the privacy, including the security, of personal information we hold about you seriously. This privacy notice is designed to inform you about how we collect personal information about you, and how we use that personal information. You should read this privacy notice carefully so that you know and understand why and how we use the personal information we collect and hold about you.
If you have questions about this privacy notice or issues arising from it, then you should contact Hugo Morisetti at hello@thewashingmachineproject.org. They are responsible for matters covered in this privacy notice.
We may update this privacy policy from time to time. This version was last updated on April 10, 2022.
1: Key Definitions
The key terms that we use throughout this privacy notice are defined below, for ease:
Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected, stored, and stored and how it is used.
Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example, or providing an email marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer-base).
Personal Information: in this privacy notice we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information which has been anonymized.
Data protection principles
In relation to your personal data, we will:
process it fairly, lawfully and in a clear, transparent way
collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
only use it in the way that we have told you about
ensure it is correct and up to date
keep your data for only as long as we need it
process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.
Types of data we process
We hold many types of data about you, including:
your personal details including your name, address, date of birth, email address, phone numbers
your photograph
gender
marital status
whether or not you have a disability
information included on your CV including references, education history and employment history
documentation relating to your right to work in the UK
driving licence.
How we collect your data
We collect data about you in a variety of ways including the information you would normally include in a CV or a job application cover letter, or notes made by our recruiting officers during a recruitment interview. Further information will be collected directly from you when you complete forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
Personal data is kept in personnel files or within the Company’s HR and IT systems.
Why we process your data
The law on data protection allows us to process your data for certain reasons only:
in order to perform the employment contract that we are party to
in order to carry out legally required duties
in order for us to carry out our legitimate interests
to protect your interests and
where something is done in the public interest.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
We need to collect your data to ensure we are complying with legal requirements such as:
carrying out checks in relation to your right to work in the UK and
making reasonable adjustments for disabled employees.
We also collect data so that we can carry out activities that are in the legitimate interests of the Company. We have set these out below:
making decisions about who to offer employment to
making decisions about salary and other benefits
assessing training needs
dealing with legal claims made against us
If you are unsuccessful in obtaining employment, your data will not be used for any reason other than in the ways explained in relation to the specific application you have made.
Special categories of data
Special categories of data are data relating to your:
health
sex life
sexual orientation
race
ethnic origin
political opinion
religion
trade union membership and
genetic and biometric data.
We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
you have given explicit consent to the processing
we must process the data in order to carry out our legal obligations
we must process data for reasons of substantial public interest
you have already made the data public.
We will use your special category data for the purposes of equal opportunities monitoring
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent, and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences when consent is withdrawn.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not be able to process or continue with (as appropriate) your application.
Sharing your data
Your data will be shared with colleagues within the Company where it is necessary for them to undertake their duties with regard to recruitment. This includes, for example, the HR department, those in the department where the vacancy is who responsible for screening your application and interviewing you, and the IT department where you require access to our systems to undertake any assessments requiring IT equipment.
Details about transfers to countries outside of the EEA (European Economic Area).
Your Personal Information may be shared with suppliers, manufacturers and delivery agencies outside of the EEA. If any Personal Information is transferred outside of the EEA then we will ensure that safeguards are in place to ensure that a similar degree of protection is given to your personal information, as is given to it within the EEA, and that the transfer is made in compliance with data protection laws.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with data protection requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for and this will depend on whether or not you are successful in obtaining employment with us.
If your application is not successful and we have not sought consent, or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for [insert retention period] once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for 1 year once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdraw your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
· the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
· the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
· the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
· the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
· the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
· the right to portability. You may transfer the data that we hold on you for your own purposes
· the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
· the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact our Data Protection Officer.
Making a complaint
The supervisory authority in the UK for data protection matters is the Information Commissioner’s Office (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.
Data Protection Officer
The Company’s Data Protection Officer can be contacted on hello@thewashingmachineproject.org.