Capco Job Candidate Privacy Notice
(Versions of this Notice can be accessed in French, German, Italian, Polish, Portuguese and Slovak here)
Purpose and legal basis for processing
Capco’s purpose for processing this information is to assess your suitability for a role at Capco.
Where processing takes place in the UK or EU, or you are a resident of the UK or EU, the legal basis we rely on for processing your personal data is article 6(1)(b) of the EU General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) which relates to processing necessary to perform a contract or to take steps at your request, before entering a contract.
The legal basis we rely on to process any information you provide as part of your enquiry or application which is special category data, such as health, religious or ethnic information, is article 9(2)(b) of the GDPR, which also relates to our obligations in employment and the safeguarding of your fundamental rights and article 9(2)(h) for assessing your work capacity as an employee.
What will we do with the information you give us?
We’ll use all the information you provide during the recruitment process to progress your application with a view to offering you an employment contract with us, or to fulfil legal or regulatory requirements if necessary.
We’ll use the contact details you give us to contact you to progress your enquiry or application. With the exception of any equal opportunity information, we’ll use the other information you provide to assess your suitability for the role.
This may include sharing your information with one or more of our clients, whose account you may be assigned to or considered for, including your, CV, details of your qualifications, relevant experience and skills, identification documentation, references and background and criminal record checks (where applicable).
Where applicable, we may also share your information with the data processors detailed below.
Please also visit the ‘With whom do we share your personal data?’ section of the Capco Privacy Notice: https://www.capco.com/Data-privacy-notice
Capco does not sell personal information and did not sell personal information in the previous twelve 12 months.
What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not keep it longer than necessary.
With the exception of the equal opportunities information mentioned below, the information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask but it may affect our assessment efforts if you don’t.
Application stage
All job application details submitted to Capco, either by yourself, using one of our online application systems, via a recruitment agency on your behalf, by one of Capco’s recruitment team after discussing a job opportunity with you or via Capco’s employee referral scheme, will be managed by Capco’s recruitment team and processed on our candidate application management platform. See our ‘data processor’ section below for further information about the platform.
We ask you for your personal details including name and contact details. We’ll also ask you about your eligibility to work in the country concerned, previous work experience, education, referees and for answers to questions relevant to the role. Our recruitment team and relevant business lead will have access to all this information.
You may also be asked to provide equal opportunities information. This is not mandatory – if you don’t provide it, it won’t affect your application. We won’t make the information available to any staff outside our recruitment team, including business leads, in a way that can identify you. Any information you provide will be used to produce and monitor equal opportunities statistics.
Shortlisting
Our recruiters and business lead shortlist applications for interview. The business leads will not be provided with your equal opportunities information if you have provided it.
Assessments
We may ask you to participate in assessment days; case studies; attend an interview (including by recorded video); or a combination of these. Information will be generated by you and by us. For example, you might complete a written assignment, or we might take interview notes. This information is held by us.
If you are unsuccessful after assessment for the role, we may ask if you would like your details retained in Capco’s own talent pool. If you say yes, we may proactively contact you should any further suitable vacancies arise.
Employment Offer
If we make an offer of employment, we’ll ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to employment. We must confirm the identity of our staff and their right to work in the relevant country, and seek assurance as to their trustworthiness, integrity and reliability.
You must therefore provide:
- Proof of ID (Personal ID Card, Passport, Birth Certificate)
- Proof of Right to Work in country where job is based
We may also perform the following, subject to local laws and practices:
- Criminal Record check (searching up to 7 years of address history)
- Electronic ID Verification check
- Credit & Bankruptcy checks (searching up to 7 years of address history)
- Global Financial Sanctions checks
- Compliance checks, including the Office of Foreign Assets Control (OFAC)
- Directorship & Media Searches
- Education & Professional Qualifications checks
- Checking up to 7 years of Employment References (gaps of over 1 month to be verified)
How long is the information kept for?
This will depend on whether your application is successful or not (unless we state otherwise in our ‘data processor’ section below):
Successful Recruitment Candidate Information (including CV’s, applications, interview notes, psychometric test data) will be destroyed 12 months after the end of employment. Except in the United States, where candidate information is retained for 24 months. Eligibility documents (identity, right work in country) and background checks (including personal references) are typically kept for 5 years after the end of employment, or longer to comply with local laws. Please refer to your local Capco Recruitment Team for further information.
Unsuccessful Recruitment Candidate Information (including third party referee details provided by the applicant) will be destroyed 12 months after the last action unless you consent for information to be held for longer. Except in Poland, where candidate information is retained for 6 months and in the United States for 24 months.
How we make decisions about recruitment?
At the initial application stage we may automatically decline your on-line application if you fail to satisfy any relevant legal requirements for employment (e.g. You state you do not have the legal right to work in the country where the role exists).
With your specific agreement we may use on-line behavioural and cognitive assessments to help us understand your personality traits, your general mental ability and capacity for critical thinking. All results are personally analysed by one of our fully trained recruitment team.
Final recruitment decisions are made by members of our recruitment team and business leads. With the exception of any equal opportunity information, we take account of all the information gathered during the application process.
You can ask about decisions on your application by speaking to your contact in our recruitment team.
Your rights
As an individual, you have certain rights regarding your own personal data.
For more information on your rights, please see the ‘Your Data Protection Rights’ section of the Capco Privacy Notice: www.capco.com/Data-privacy-notice
If you are a resident of the US State of California, more information about applicable rights can be accessed here: CCPA (capco.com)
Capco’s Data Protection Officer can be contacted at: ask.capco.dpo@capco.com
Do we use any data processors?
Yes – we use several processors to provide elements of our recruitment service for us as follows:
On-line Candidate Application Management Service
We use Greenhouse’s candidate application management platform. You can access their Privacy Policy here: www.greenhouse.io/privacy-policy.
Where laws allow, we use DocuSign to provide successful candidates with an electronic offer letter and other paperwork relating to the hiring process. You can access their Privacy Policy here: https://www.docusign.com/company/privacy-policy.
Recruitment Agencies and Talent Pools
We have relationships with a number of recruitment agencies and talent pools and where you have applied for a position with Capco through such agency or registered with a particular talent pool, you should approach them directly for information on their privacy policy and data retention periods.
Video Interviews
In the UK we use Launchpad Recruits Ltd.’s recorded video interviewing platform for certain roles. You can access their Privacy Policy here: https://www.launchpadrecruits.com/privacy-policy. We instruct Launchpad to delete your personal data, including all video records, after 12 months.
Employment Vetting
Capco use the following range of providers, depending on your location and operational requirements:
First Advantage. You can access their respective Privacy Policies for candidates here: https://fadv.com/privacy-policy/
HireRight. You can access their Privacy Policy here: www.hireright.com/emea/legal/privacy-policy/emea-and-apac-candidate-policy
Sterling Talent Solutions. In the US their service also includes I-9 eligibility checks. You can access their Privacy Statement here: https://privacy.sterlingcheck.com/
Vero Screening. You can access their Privacy Policy here: https://veroscreening.com/privacy-policy/
Please contact your local recruitment team contact if you wish to identify the provider relevant to your application.
Notice Version: 2 MARCH 2023
