Lightship Employee Recruitment Privacy Notice
Last Revised: 17 September 2021
Table of Contents
- Contact Details
- Personal Information Collected
- Sources of Information
- How we use personal information
- Why we use personal information
- How we use special category personal information
- Why we use special category personal information
- Information about criminal convictions
- Information that we share
- Retention of your information
- Where your information will be held
- Your rights
- Appendix A
This privacy notice applies to personal information collected by Lightship, Inc. 222 Pacific Coast Highway; El Segundo, CA 90245 (Lightship US) and/or Lightship Clinical Research Limited (company number 13198533), 11th Floor, Whitefriars Lewins Mead, Bristol, England, BS1 2NT, United Kingdom (Lightship UK), and/or other subsidiary of Lightship US in the United Kingdom (UK) or European Economic Area (EEA), as identified in the job description (together, Lightship/we/us/our) in connection with a job application submitted by you orotherwise during the recruitment process. Where you are applying for a role with Lightship UK or another Lightship company in the UK or EEA, that company will be the “data controller” of the personal information collected about you.
Lightship US acts as joint data controller of your personal data, with Lightship UK or other Lightship US subsidiary, for purposes of management and strategic planning when recruiting personnel. Nevertheless, Lightship UK or the other subsidiary is responsible for providing you with this privacy notice and with responding to your requests mentioned in section 12 below.
If you have any queries in relation to any matters concerning this notice, please contact our HR team or the Data Protection Officer.
Contact details of the HR team are in the job description.
Where you are located in the UK or EEA, the Data Protection Officer can be contacted via firstname.lastname@example.org.
Personal Information Collected
We collect the information (including special categories of information) set out at Appendix A about you during the recruitment process. If we offer you a position, then we take up references and, for certain positions, we will obtain criminal records and background checks. At this point, we would ask you to work with our third-party employment verification service who will conduct the necessary background checks (subject to their privacy notice)
If you fail to provide certain information when requested, we will not be able to progress your application.
Sources of Information
We obtain your personal information from you; your previous employers or other referees you have named; recruitment and search agencies or third-party job platforms; LinkedIn or other social media; and from credit references agencies or other background check agencies. We create information about you in the course of the recruitment process.
How we use personal information
We use your personal information to progress the recruitment process. This includes soliciting applications for positions, communicating with you including to arrange and conduct interviews and to offer you the position where we decide to do so, assessing and making a decision about your suitability for a role. We will ask you about key skills or requirements needed for a specific role. If you do not have these key skills or meet these requirements you may not be able to proceed with the application.
We will also use your information to comply with legal and regulatory requirements. These requirements include duties under employment, social security, social protection, and tax legislation and duties imposed under health sector regulation including to protect patients or as relevant to the conduct of clinical trials.
We will also use your information to comply with our contractual obligations to our customers (to the extent permitted by applicable law). This may include conducting suitable criminal records and background screening checks (if permitted by applicable law).
Why we use personal information
We will use the information collected from you because:
- it is necessary for us to do so before entering into a contract with you;
- we need to use your information to comply with a legal or regulatory obligation; or
- it is necessary for our or a third party’s (such as a customer or the patients involved in clinical trials) legitimate interest in ensuring the effective administration and management of the recruitment process; ensuring we hire a suitable individual for a role; and dealing with disputes and claims and taking legal or other professional advice.
How we use special category personal information
We will use your special categories of personal data to consider if we need to provide appropriate adjustments during the recruitment process and to ascertain your fitness to work; for equal opportunity monitoring purposes (unless you have asked us not to do so in which case, we will have a reasonable period in which to stop using the data); to promote or maintain diversity at senior levels; or to comply with any legal or regulatory obligation.
Why we use special category personal information
We will use special categories of personal information collected about you because:
- you have provided your explicit written consent
- it is necessary in connection with employment or social security law;
- we need to do so to carry out our legal obligations;
- it is necessary for the establishment, exercise or defence of legal claims in relation to court cases; and/or
- there is a substantial public interest.
Information about criminal convictions
If we offer you a position, we will use a third-party vendor to work with you to obtain information in relation to unspent criminal convictions and we may carry out criminal background checks. At that point, we will ask for your consent to do so.
We use this information and these checks to assess your suitability for a regulated role; to protect your interests, our interests and third-party interests, including of our customers and patients involved in clinical trials; and/or where it is necessary in relation to legal claims.
We are allowed to use your personal information in this way:
- where it is necessary to carry out our employment rights and obligations;
- where it is necessary for health or social care purposes;
- it is needed in the public interest to prevent any unlawful act from potentially occurring and this must be carried out without your consent;
- it is needed in the public interest to protect the public against malpractice, seriously improper conduct, unfitness, or incompetence; or
- you have given your consent.
Retention of your information
We will retain your personal information for the duration of the recruitment process and for the length of any applicable limitation period for claims which might be brought against us later.
If you are successful in applying for a position, your personal information will be retained for a further period in connection with your employment. This will be as set out within our Employee Privacy Notice which will be made available to you on employment.
If your application for a particular position is not successful, unless you object, we may keep your information for up to a year in case we wish to contact you about another position.
Where your information will be held
Your personal information may be transferred to or accessed by:
- Lightship group companies in the UK, EEA or countries where the adequate protection of your personal is ensured in accordance with the General Data Protection Regulation (GDPR) or the GDPR applied into UK law (UK GDPR);
- Lightship group companies outside those countries where the adequate protection of your personal is ensured, including the United States of America, based on the conclusion of standard contractual clauses approved under the GDPR or the UK GDPR;
- recruitment, background check and online test providers, IT or other service providers in the UK, EEA or countries where the adequate protection of your personal is ensured in accordance with the GDPR or the UK GDPR;
- recruitment, background check and online test providers, IT or other service providers, outside those countries based on the conclusion of standard contractual clauses or binding corporate rules approved under the GDPR or the UK GDPR.
Prior to any transfer of your personal information subject to the standard contractual clauses or binding corporate rules, we will assess and confirm that those protections are effective in light of the legal regime in the data recipient’s jurisdiction and, if necessary, adopt supplementary technical, organisational, or contractual measures.
You can request copies of the standard contractual clauses from our HR team or Data Protection Office (see section 1).
You have certain rights over your information if you are applying for a role with Lightship UK or a subsidiary of Lightship US established in the EEA, or if you are responding to an invitation or advertisement that Lightship US was intending for applicants from the UK or EEA. These rights are explained below but please note that they are subject to certain exemptions.
- Right of access – the right to request a copy of the personal information we have about you and to request supporting information explaining how the personal information is used.
- Right of rectification – the right to request that we rectify inaccurate personal information about you.
- Right of erasure – the right to request that we erase personal information about you in certain circumstances. These include where we are using personal data because you have given us your consent and where you have objected (see item (g) below) to our use of your personal data based our or a third party’s legitimate interests and we don’t have an overriding reason to continue to use it.
- Right to restrict processing – in some situations, you have the right to request that we do not use the personal information you have provided (e.g., if you believe it to be inaccurate).
- Right to data portability – you the right to receive certain of your personal information in a structured, commonly used and machine-readable format and to transmit such information to another controller but only if we are using your information based on your consent or to perform a contract with you.
- Right to withdraw consent – where we process your personal information based on your consent, you have the right to withdraw consent at any time. However, this will not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, even in case of a withdrawal we may continue to use your personal information as permitted or required by law.
- Right to object – where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we are entitled to continue processing your information based on our legitimate interests if we have compelling legitimate interests which override yours or where this is relevant to legal claims.
If you would like to exercise any of these rights, please get in touch with our Data Protection Officer (using the details in section 1 above). You are also free to lodge complaint with the supervisory authority or regulatory body, should you feel that we process your personal information in a way that is against applicable law.
We may ask you to verify your identity before carrying out a request.
We will collect the following personal information about you:
Category of Personal Information
- Information provided in your resumé, application form, covering letter and during the interview process.
- Information collected or created by us during the recruitment process.
- If we offer you a position, special categories of personal data.
Personal Information Collected
- Your name, home address, national ID, personal email address, phone number(s), education, qualifications, work experience details and references.
- Interview notes, test scores and correspondence between us.
- Immigration/naturalisation records and right to work information (if these disclose racial/ethnic origin information).
We may collect the following personal information about you if you choose to provide this information to us or if we need to collect this information for the specific role you have applied for:
Category of Personal Information
- Special Categories of Personal Data
- Information collected during the recruitment process.
- If we offer you a position, Information about criminal convictions you provide during the recruitment process and collected if we carry out criminal records checks.
- If we offer you a position, driving license checks (which may include information about criminal convictions) conducted if either the role applied for involves driving or as part of a remuneration or benefits package you would receive a company car or other car allowance.
Personal Information Collected
- Information about your racial or ethnic origin, religious or philosophical beliefs, physical or mental health or disabilities, or sexual orientation.
- Marital status, date of birth and gender.
- Criminal convictions.
- Driving license number, driving license details (such as expiration date) and details of recent accidents, driving penalties, violations or criminal convictions associated with that driving license as well as the status of the driving license.