Privacy Policy

Holy Trinity Brompton, Alpha International, St Paul’s Theological Centre and Church Revitalisation Trust are independent charities that have a shared heritage. We refer to the charities collectively as the HTB Group (HTBG), but they do not form part of a group within a technical legal definition. The HTBG work cooperatively and collaboratively with many shared systems, processes and policies. In light of the close partnership, shared offices and infrastructure the constituent charities of the HTBG have agreed to adopt a common Data Protection Policy Framework (DPPF) and have entered into a formal data sharing agreement to regulate the extent to which data may be shared between the charities and the protection and procedures in place to regulate this sharing of data.

This Privacy Notice explains how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker, contractor, intern or volunteer). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

We will comply with data protection law and principles, which means that your data will be:

• Used lawfully, fairly and in a transparent way.

• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

• Relevant to the purposes we have told you about and limited only to those purposes.

• Accurate and kept up to date.

• Kept only as long as necessary for the purposes we have told you about.

• Kept securely.

In connection with your application to work or volunteer with us, we will collect, store, and use the following categories of personal information about you:

• The information you have provided to us in your curriculum vitae and covering letter.

• The information you have provided on our application form, including name, address, telephone number, personal email address and qualifications.

• Any information you provide to us during an interview.

• If your role requires a test, the results will be kept on file

We may also collect, store and use the following types of more sensitive personal information:

• Information about your health, including any medical condition, health and sickness records.

• Information about criminal convictions and offences.

We collect personal information about candidates from the following sources:

• You, the candidate.

• Recruitment agencies, from which we collect the following categories of data: name, address, personal email address, qualifications and any other data they provide.

• Disclosure and Barring Service in respect of criminal convictions.

• Your named referees, from whom we collect the following categories of data: referee’s personal opinions on candidates attributes, candidate’s involvement with Church, any personal concerns the referee might have, referee’s experience with candidate in a work environment.

We will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the role.

• Carry out background and reference checks, where applicable.

• Communicate with you about the recruitment process.

• Keep records related to our hiring processes.

• Comply with legal or regulatory requirements.

It is in our legitimate interests to decide whether to appoint you to a role since it would be beneficial to our business to appoint someone to that role.

We also need to process your personal information to decide whether to enter into a contract of employment with you.

Having received your CV, covering letter and any other required application materials including results from any tests which you took, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references before confirming your appointment.

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

We will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made for an interview and any induction days.

• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

In certain situations, it may be necessary to process information about any criminal convictions you may have.

We will collect information about your criminal convictions history if we are considering offering you a role (conditional on checks and any other conditions, such as references, being satisfactory) working with us.

In line with our Safeguarding Policy, all those who work regularly with children and vulnerable adults must have, where appropriate, an enhanced criminal record check (with / without a check of the barred list, as appropriate).

We will ask you to undertake an enhanced criminal record check, if your future role engages in work which is included in the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (as amended) that is ‘work with children’ and / or ‘work with adults’ as defined in the Police Act 1997 (Criminal Records) Regulations 2002 (as amended). Examples of such roles include Clergy, the Kids and Youth Team, Shelter workers or any other ‘Church Officer’ position working with children or adults with vulnerabilities.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Failure to reveal information that is directly relevant to the position sought could lead to withdrawal of an offer of employment.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Why might you share my personal information with third parties?
We will only share your personal information with Thirtyone:eight for the purpose of processing your DBS check. Our third-party service provider and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service provider to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

If you would like to know more about how Thirtyone:eight processes your personal details, please see their privacy policy via this link.

Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

How long will you use my information for?
We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to appoint you to role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

Your rights in connection with personal information
Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Recruiter in writing.

If you have any questions about this privacy notice or how we handle your personal information, please contact GDPR@htb.org. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.