1.1 Our mission is to increase disability inclusion during the recruitment process and in the workplace, ensuring that candidates, employees and employers understand their rights and responsibilities. We act in accordance with the Equality Act 2010, and process data in order to further its objectives in respect of disability.
1.2 Every individual who registers with us is disabled according to the UK legal definition, and is therefore entitled to reasonable adjustments in recruitment and the workplace. In order to ensure you receive these, you trust us with sensitive information about your health. Your privacy is incredibly important.
1.3 The data we hold about you is collected, retained and generated in order to fulfil one or more of our purposes, and if you are an individual to whom we are providing support, we ask that you explicitly consent to our using your data for each of these purposes.
1.4 This privacy notice is intended to provide individuals receiving support from us in respect of their disability or participating in one of our programmes, with an understanding of how and why we hold and process their data, and their rights around this processing, and for our employee partners and university partners.
2. Why we hold your data
2.1 To assist you in the recruitment process for internships, graduate programmes, scholarship programmes and experienced hire roles, through a variety of services, including personalised support, adjustments advice and advocacy, skills enhancement and placement through one of the programmes we run with our employer partners.
2.2 To support you with adjustments and support you may need in the workplace, including advocating or negotiating on your behalf with an existing or potential new employer. This includes EmployAbility acting as a workplace adjustment. It also includes assistance in the recruitment process for experienced hires.
2.3 To provide you with promotional material about our events, opportunities, services, and legal updates.
2.4 To invite you to participate in research projects, in order to better inform and provide evidence-based information about issues such as the adequacy of adjustments, the impact of specific disabilities, mental health at work, patterns of discrimination, in order that we can act on evidence-based information. All such studies to be anonymous at the point of publication in respect of the individuals who participated.
2.5 In order that you can participate in our EmployAbility Alumni Programme. Membership of this programme does not require us to hold your health information.
2.6 In order that you can apply for a mentoring programme with one of our employer partners. This may involve us collecting data about your health if you require any adjustments to apply for a programme, or to participate in it.
2.7 Because we are auditing the disability-related practices of your employer, whether as to its recruitment and workplace adjustments processes, its wider attitude and culture towards disability, or identifying issues relating to disability inclusion, and you have been asked to participate in this audit.
2.8 Because we are providing a service to your employer, and we are working with you as a contact and/or team member in relation to that service.
2.9 To provide our employer and university partners with information about the volume and type of support provided to their students, graduates, candidates and employees as part of a contract with them.
2.10 To understand the methods by which individuals registering with us became aware of our services.
3. The types of data we hold
3.1 Information you provide to us. This includes basic personal information (such as your name, your qualifications, your phone number, your email address, your work history); health information relating to your disability; and any other information you provide to us.
3.2 Information we generate about you. This includes our assessment of your adjustment needs, our assessment of your suitability for any role or event to which you apply or any alternative which we think may be more appropriate.
3.3 Information from third parties. This includes feedback from our partner employers and other organisations you have applied to and to whom we have advocated on your behalf.
3.4 Your opinions and experiences around disability, whether your own, or that of co-workers are applicants during the recruitment process, where you choose to provide us with that information as part of an audit or your employer, a research survey in which you are participating, or as part of our Campus Ambassador Programme, our Alumni Programme, or by providing a testimonial, article or video for our website.
4. How long we keep your data
4.1 We hold data for different lengths of time, depending on the purpose for which we have it. To ensure we don’t hold data for longer than we need to, we have specific retention periods. At the end of any such period, we will write to let you know that we will erase the data we hold on you for that purpose, unless you wish us to continue to hold. If you do, we’ll ask you to provide renewed specific consent to that. The length of time for which we hold information about you is included when you provide us with your consent to hold and process your data for a particular purpose, and the time limits are also set out in this section. You can withdraw your consent at any time and ask us to erase your information.
4.2 To assist you in the recruitment process for internships and graduate positions through a variety of services, including personalised support, adjustment advice and advocacy, skill enhancement and placement through one or more of the programmes we run with our employer partners, we hold your data for six years from the date on which you register with us. At the end of this period, we request you provide us with renewed consent. If we do not receive your consent after one calendar month, we delete your information.
4.3 If you register with us for support with adjustments and other support in the workplace, including advocating or negotiating on your behalf with an existing or potential new employer for a non-graduate role, including where EmployAbility acts as a workplace adjustment we hold your data for four years. At the end of this period we request you provide us with renewed consent. If we do not receive your consent after one calendar month, we delete your information.
4.4 If you do not register with us, but use our service on a one-off basis because you are applying to an employer organisation who provides you with our contact details to get adjustments as part of its recruitment process, or because your employer has provided you with our contact details to advise you on workplace adjustments, we hold your data for one year. At the end of this period we delete your information.
4.5 To provide you with promotional material about our events, opportunities, services, and legal updates, we hold your data for four years. At the end of this period we request you provide us with renewed consent. If we do not receive your consent after one calendar month, we delete your information.
4.6 To participate in research projects we hold your information for 10 years. At the end of this period we request you provide us with renewed consent. If we do not receive your consent after one calendar month, we delete your information.
4.7 To participate in our EmployAbility Alumni programme. 10 years, at the end of which period we request you provide us with renewed consent. If we do not receive your consent after one calendar month, we delete your information.
4.8 If you are participating in an audit of your employer, we will retain your information until we have provided our findings and recommendations to your employer. Any information you provide us with will be anonymised and/or transformed into a form which does not allow for indirect identification, within two months of you providing it to us. Depending on the way data is collected, the questions asked, and the way in which the audit is carried out, we may ask for your consent to process your personal data.
4.9 If we are providing you with a contracted service, we will retain communications with members of the team for one year after the fulfilment of the contract, or in the case of an ongoing relationship, one year after the end of that relationship, unless we agree otherwise by contract, or by asking for your consent to retain your contact details.
5. Your rights
5.1 We can delete any information we hold about you if you ask us to do so. We will do this within thirty days of receiving your request, unless we need to hold your data in order to meet a legal obligation.
5.2 You can withdraw consent for any type of processing of your information, or retention of any category of information, at any time. We will process your request within thirty days, and delete your information, unless we need to hold it in order to meet a legal obligation.
5.3 You can ask us to rectify any data we hold on you, or you can rectify it yourself.
5.4 If you think we have infringed your rights, you can lodge a complaint with the Information Commissioner. We can provide you with the ICO’s contact details if you require.
6. How we protect your information
6.1 We have extensive controls in place to maintain the security of our information and information systems. The information we process is protected with safeguards appropriate to the sensitivity of the information and our categorised risk assessment.
6.2 Only authorised employees have access to data which is not in the public domain. Appropriate controls are in place for accessing this data.
6.3 All authorised employees with access to data are provided with data protection and security training, and are required to act in accordance with data protection legislation, which includes the UK GDPR, the GDPR and the Data Protection Act 2018. Employees are prohibited from any unauthorised use or disclosure of your data to a third party.
7. Transfer of data outside the UK
7.1 In the vast majority of cases, it will not be necessary for us to transfer your data outside of the EEA, either directly or indirectly. However, sometimes it may be necessary, and where it is, we will ensure that necessary additional protective measures are in place.
7.2 If you wish to apply for one of our employer partners’ advertised roles in another jurisdiction, subject to our initial screening, we will pass information about you to the employer’s office in the local jurisdiction where the role is advertised or will be carried out. This will include information about the adjustments you need, but will not include information about your disability. We will ask for your explicit consent for any transfer outside the EEA, either by us directly, or indirectly by one of our UK partners.
7.3 We can provide you with more information about the protection given to your data when it is to be transferred outside the EEA by contacting us on firstname.lastname@example.org. Please note that this information will be provided in the context of a specific overseas role to which you have applied.
8. Disclosure to third parties
8.1 We may discuss your application with any of our employer partners to whom you choose to apply for a role or other opportunity such as an insight day, event or mentoring programme. We will monitor your application, and discuss the adjustments you require, based on the health information you have given to us, including that held on our database. In most cases we will not tell a potential employer about your disability. If it is necessary to tell an employer about your disability in order to ensure you receive adequate adjustments, we will seek your express consent beforehand. Our employer partners may provide feedback on applications. They may retain information about you if you are unsuccessful, in case you are suitable for a future role. We ask you to consent to this whenever you make an application.
8.2 We may have similar discussions with any third party employer to whom you choose to apply for any position, who is not one of our partners, but to whom we advocate on your behalf, and at your request. Such employers may provide feedback to EmployAbility on occasion. We will ask you to consent to this beforehand.
8.3 We do not sell, share or lease your personal information, other than as described in this privacy notice, unless you give us specific permission to do so.
8.4 We may be obliged to disclose your personal information in order to meet a legal or regulatory requirement.
9.1 When you register with us, you receive a welcome email which describes the information we will send to you by email about live opportunities and other news. If you don’t wish to receive these emails, you can opt out at any time, either via the welcome email, or by clicking the unsubscribe link in any email you receive.
11.1 EmployAbility has a designated email address which you can contact about any matters relating to protection of your data. This includes subject access requests, requests for your data to be deleted, withdrawing of consent in respect of processing a particular type of data, retaining data for a particular period, or any reason for processing your data. You can also use this email address for questions or concerns. We undertake to answer you or carry out your request promptly, but always within thirty days. We will also do our best to resolve any concerns you may have, or clarify anything you don’t understand.
11.2 If you are based in the EEA and have used our services to access a role in the EEA or receive support at work in the EEA and wish to make a request about your data, or you are an EEA regulator, you can contact our EU representative should you prefer. Our EU representative will work with us to ensure all queries and requests are dealt with quickly and effectively.