1. Summary
Croydon Drop In operates a recruitment and staff management system called Unity. This notice applies to the personal information held in that system about applicants, staff and referees.
This summary is not a substitute for the notice. The detail is in the sections that follow.
- We collect the information we need to run a fair recruitment process and to meet our safeguarding and employment obligations, and no more.
- The panel scoring your application cannot see your name, your contact details or your criminal record declaration. This restriction is enforced by the database, not by internal practice.
- Equality monitoring is optional. Hiring managers never have access to the answers, which are held separately from your application and cease to be identifiable when that application is deleted.
- You may obtain a copy of the information we hold about you, and ask us to correct or delete it.
- You may complain to us and, at any time, to the Information Commissioner.
Section 7 sets out who has access to which information at each stage of recruitment, and is the section most applicants will want.
2. Who we are and how to contact us
Croydon Drop In is the data controller for the information described in this notice. We determine what information is collected and the purposes for which it is used, and we are accountable for it under the UK GDPR and the Data Protection Act 2018.
Contact details
Croydon Drop In, 132 Church Street, Croydon, London CR0 1RF
Email: enquiries@croydondropin.org.uk
Telephone: 020 8680 0404
Registered charity number 1049936
Information Commissioner’s Office registration reference ZA315283
Croydon Drop In has appointed a Data Protection Officer in accordance with Article 37 of the UK GDPR. The post holding that role is the Director of Finance and Business Operations. Requests, enquiries and complaints about your information should be addressed to the Data Protection Officer using the email address above, and will reach them whoever holds the post.
We identify the post rather than the individual holding it. This is deliberate: a notice that names a person becomes inaccurate the day that person changes role, and usually without anybody noticing.
This notice covers the Unity system only. It applies to applicants for employment with us, to our staff, and to referees who are asked to provide a reference. It does not cover the services Croydon Drop In provides to young people, which are the subject of a separate notice.
3. Information we collect from applicants
We hold three separate categories of information about applicants, and we keep them separate: your profile, each application you submit, and equality monitoring. This section describes the first two. Equality monitoring is dealt with in section 4.
3.1 Account information
An account is required in order to apply. We hold your email address and a record of whether it has been confirmed. We do not store your password. The authentication system holds a one-way cryptographic hash, which cannot be reversed.
3.2 Profile information
Your profile is completed once and reused for each application. It contains the following:
- Your first name and last name, your preferred title, and your pronouns if you provide them.
- Your telephone number and email address.
- Your address: street, town or city, county, postcode and country.
- Your education, if you choose to provide it: the type of institution (secondary school, college or further education, university), its name, the dates of attendance, and the qualifications and grades obtained. Education is optional and may be left blank without affecting your application.
- Short courses and other training: the provider, the course name, and the dates.
- Your employment history: each employer’s name and address, the position held, the dates, an outline of your duties, and your reason for leaving.
- Your referees: name, email address, postal address, telephone number if provided, how they know you, whether they are your most recent employer, and whether we may approach them if you are shortlisted.
- A CV, if you choose to upload one.
Information we do not collect at application stage
- Date of birth and National Insurance number. These are collected only from candidates who are being appointed, so that they are not held for unsuccessful applicants.
- A photograph. A photograph would defeat the blind shortlisting described in section 7, and the system therefore provides no means of uploading one.
- Current or previous salary. Setting pay by reference to previous pay carries forward existing pay inequality, and does so disproportionately for women and for those returning from a career break.
3.3 Application information
Each application asks a short set of questions, since the substantive information is held in your profile. Depending on the post, these are:
- Your availability to start.
- Whether you wish to be considered for a job share.
- Whether you require permission to work in the UK.
- Any adjustments you require in order to take part in the recruitment process.
- Where you saw the post advertised.
- Whether you hold a full current driving licence and have use of a vehicle. Asked only where driving is an essential requirement of the post.
- Whether you have previously been dismissed by an employer and, if so, the circumstances.
- Any explanation you wish to give of gaps in your employment history.
- Relevant experience gained otherwise than in paid employment.
- A declaration of criminal convictions and cautions. See section 5.
- Your supporting statement.
Information provided in the adjustments field is used only to make arrangements for your participation in the recruitment process. It forms no part of the selection decision and is not disclosed to the panel scoring your application.
3.4 Information generated by the system
Where you are invited to interview, the system compares the dates in your employment history and identifies to the panel any gap exceeding two months, together with any explanation you have provided. This is a safer recruitment measure: unexplained gaps must be explored at interview, and identifying them by inspection is unreliable. The prompt exists to enable a conversation rather than to count against you, and it is not disclosed during shortlisting.
3.5 Information generated during the recruitment process
We keep a record of each application and its progress: its status, the scores and written assessments recorded by those who assessed it, any interviews arranged and their outcome, the correspondence sent to you by the system, and any offer made, including the terms offered and whether it was accepted. Offers of employment are executed electronically.
Where we take up references, we hold the referee’s name, email address, organisation, job title and relationship to you, together with the content of the reference. References are taken up for candidates we propose to appoint, and only in respect of referees you have authorised us to approach, save that safer recruitment requires us to approach your most recent employer.
3.6 Technical records
Unity maintains a security log. It records sign-ins, failed sign-in attempts, password changes and administrative actions, together with the time, the IP address from which the request originated, and the browser and device used. Certain of these records retain a truncated IP address rather than the full address.
4. Equality monitoring
We invite all applicants to answer a set of equality, diversity and inclusion questions. These questions are optional, and whether you answer them has no bearing on your application.
The questions cover:
- Your gender, with the option to describe it in your own words.
- Whether the gender you identify with is the same as the sex registered at birth.
- Your ethnic background, using the categories used in the national census.
- Whether you consider yourself to have a disability or health condition within the meaning of the Equality Act 2010.
- Your sexual orientation.
- Your religion or belief.
- Your age band.
- Whether you have caring responsibilities.
- Whether you are an armed forces veteran.
Each question offers a “prefer not to say” option, and the section may be skipped in its entirety.
4.1 Special category data
Information about your ethnicity, disability, sexual orientation, religion or belief, and whether your gender corresponds to the sex registered at birth, is special category data within the meaning of Article 9 of the UK GDPR. It attracts additional protection, and we process it only with your explicit consent, given by the confirmation on the form and recorded with the date and the wording consented to. Section 8 states the conditions relied on.
4.2 Access by hiring managers
Hiring managers and panel members have no access to equality monitoring answers at any stage: not at shortlisting, at interview, at offer, or subsequently. The answers are stored separately from your application, and the database will not disclose them other than to staff holding the relevant data protection permission.
4.3 Monitoring answers are not held against your identity
Equality monitoring answers are not stored against your name or your account. They are held as a separate record: that an application was submitted for a given vacancy, on a given date, by a person who gave the answers recorded.
That record retains a reference to the application it accompanied, and does so only for as long as the application itself is retained. The reference exists so that we can establish whether applicants from any group are shortlisted or appointed at a different rate from others, which is the purpose of collecting the information. When the application is deleted at the end of its retention period, the reference is removed as part of that deletion, and what remains identifies no one.
It follows that we count applications rather than individuals. Three applications from the same person produce three sets of answers, because what we report is the composition of the applicant pool for each vacancy.
4.4 Effect on your rights of access and erasure
While your application is still held, your monitoring answers can be located, and you may request a copy of them or ask for them to be deleted. Once the application has been deleted at the end of its retention period, they can no longer be located: the reference has been removed, and neither we nor anyone else is able to determine which record was yours.
Draft answers saved against your profile are different. They are held against your account, may be amended by you at any time, and are deleted with the account.
Because the retained answers identify no one, they are kept indefinitely, so that year-on-year comparison remains possible.
5. Criminal record information
All posts at Croydon Drop In, including administrative posts, involve contact with children and young people or with information about them. Every post is therefore subject to an enhanced Disclosure and Barring Service (DBS) check, and every application requires a declaration of convictions and cautions which would otherwise be treated as spent. These posts are exempt from the Rehabilitation of Offenders Act 1974 by virtue of the Exceptions Order 1975.
- You are not required to disclose protected (filtered) cautions or convictions. These do not appear on a DBS certificate and need not be declared. Youth cautions, reprimands and final warnings are never disclosed. If you are uncertain whether a matter requires disclosure, you may ask us in confidence before answering.
- A criminal record does not automatically preclude employment with us. We consider the nature of the offence, how long ago it occurred, its relevance to the post, and the circumstances since. Most declarations do not affect the outcome.
- Your declaration is accessible only to the staff responsible for safer recruitment. It is not disclosed to the panel scoring your application, and that restriction is enforced by the same database controls that enforce blind shortlisting.
Where you are appointed, we also hold the information obtained during pre-employment checks: your enhanced DBS certificate number, its issue date and level, whether any matter is disclosed on it, whether you are registered with the DBS Update Service, the outcome of the Children’s Barred List check, an overseas criminal records check where you have lived or worked outside the UK, a self-disclosure declaration, and, where the post requires it, a prohibition check.
Criminal offence data is not special category data, but Article 10 of the UK GDPR permits its processing only where authorised by domestic law. Section 8 states the condition relied on.
6. Information we collect about staff
Unity is not solely a recruitment system. It also holds information about those employed by Croydon Drop In.
6.1 Staff records
- Your name, work email address, job title, team, contact number and profile photograph.
- Your start date and, on termination, your end date.
- Your line manager.
- Your role in the system and the individual permissions attached to your account, together with a permanent record of every change to those permissions, by whom it was made and for what reason.
- Any notes recorded against your record.
6.2 On-site sign-in records
Staff sign in and out by presenting a phone to an NFC tag at a building entrance. Each tap records the member of staff, the building, the tag, whether the movement was an arrival or a departure, and the time. The time is recorded by the server and cannot be set from the device.
Where a member of staff does not sign out, an automated process at the end of the day closes the session and marks it as closed automatically rather than leaving it open. Corrections are made by recording an opposing entry, and never by amending or deleting the original, so that the register reflects what occurred.
Where you elect to have a device remembered so that you need not sign in on each occasion, the system stores a hashed token, a label by which you can identify the handset, and the date of last use. The token itself is disclosed to the device once and is not stored. A remembered device ceases to function 30 days after its last use, and each use extends that period to a further 30 days.
Any member of staff may see who is on site at the present time. Searching historical sign-in records and exporting the register require a specific permission.
Sign-in records are not used in relation to pay. Your pay is not calculated from them, and they are not checked against your hours.
They may, however, be used in attendance management or performance processes where a concern about a member of staff has already been raised, and in that case they are considered as part of the relevant HR process. We tell you this plainly because it is the sort of use you would not otherwise expect from a record whose stated purpose is knowing who is in a building. They are not consulted routinely, and not as a matter of course in supervision or appraisal.
6.3 Pre-employment information
Where you are appointed, we hold the pre-employment checks required by law and by safer recruitment: evidence of your right to work in the UK, photographic identification, proof of current address, evidence of any change of name, the DBS and barred list checks described in section 5, your National Insurance number, and your P45 or starter declaration. Most of these require a document to be uploaded, and that document is retained in the system.
6.4 Records of actions taken in the system
Unity records administrative actions taken within it, including the approval of a vacancy, changes to another person’s permissions, the scoring of an application and the handling of a data rights request. These records exist so that decisions affecting candidates can be accounted for, and they cannot be amended or deleted. Access to a record is not itself logged, so we are able to identify who has acted on your application but not who has viewed it.
7. Access to your information during recruitment
Shortlisting at Croydon Drop In is conducted blind. Those scoring applications do not know whose application they are assessing. Your first name, last name and email address are held in a separate table subject to its own access controls, and the database will not disclose them to a hiring manager or panel member until you are invited to interview. The hiring manager is subject to the same restriction, being the person most likely to recognise an internal applicant.
| Information | Panel and hiring manager | Recruitment administration | When access changes |
|---|---|---|---|
| Your name, contact details and email address | Withheld | Available throughout | Disclosed to the panel on invitation to interview |
| Your supporting statement and answers | Available | Available | No change |
| Your adjustments request | Withheld from the scoring panel | Available, in order to make arrangements | No change |
| Your criminal record declaration | Withheld | Available to staff responsible for safer recruitment | No change |
| Employment gaps exceeding two months | Withheld during shortlisting | Available | Disclosed to the panel on invitation to interview |
| Your equality monitoring answers | Never available | Available only to staff holding the data protection permission | No change |
Staff responsible for recruitment administration have access to your identity at every stage. This is necessary in order to arrange interviews, implement the adjustments you have requested, identify conflicts of interest, and have regard to your welfare during the process. In limited circumstances they may disclose a candidate’s identity to the panel in advance of interview.
8. Our lawful basis for processing
We are required to identify a lawful basis for each purpose for which we process your information. The table below states our lawful basis in each case, together with the additional condition relied on for special category data and criminal offence data.
| Purpose | Lawful basis and condition |
|---|---|
| Operating the recruitment process: holding your profile, assessing your application, arranging interviews, and recording the decision | Legitimate interests, Article 6(1)(f). Our legitimate interest is in filling posts fairly and being able to demonstrate how each decision was reached. We have balanced that interest against your interests and rights, which is why identities are withheld from assessors and why we do not collect a photograph, date of birth or salary history. |
| Making an offer of employment and taking up references before commencement | Steps taken at your request prior to entering into a contract, Article 6(1)(b). |
| Safer recruitment checks: references covering recent employment, enquiry into employment gaps, the criminal record declaration, and DBS and barred list checks | Legal obligation, Article 6(1)(c). We are required to carry out these checks because the work involves children and young people. |
| Right to work checks, and National Insurance and payroll starter information | Legal obligation, Article 6(1)(c). Immigration, Asylum and Nationality Act 2006, section 15, and HMRC PAYE requirements. |
| Equality monitoring | Consent, Article 6(1)(a), and explicit consent for the special category questions, Article 9(2)(a). Consent may be withdrawn at any time, subject to section 4.4. |
| Adjustments requested by you, where the information provided concerns your health or a disability | Article 9(2)(b), with the employment condition at Schedule 1, Part 1, paragraph 1 of the Data Protection Act 2018. This is necessary in order to comply with the duty to make reasonable adjustments under the Equality Act 2010. |
| Criminal record declarations, DBS certificates and barred list results | Article 10, as authorised by the Data Protection Act 2018, Schedule 1, Part 2, paragraph 18 (safeguarding of children and of individuals at risk) and paragraph 1 (employment, social security and social protection). |
| Staff records, permissions and system access | Performance of your contract of employment, Article 6(1)(b), and legitimate interests, Article 6(1)(f), in controlling access to candidate information. |
| On-site sign-in and sign-out records | Legitimate interests, Article 6(1)(f). Our legitimate interest is in knowing who is present in a building in the event of an emergency, and who is on site with young people. |
| Security logs and records of administrative actions | Legitimate interests, Article 6(1)(f), in maintaining the security and accountability of a system holding sensitive information. |
Objecting, and withdrawing consent
Where we rely on legitimate interests you have the right to object under Article 21, and we must cease processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms. Section 12 explains how to object. Where we rely on consent, you may withdraw it at any time without giving a reason and without affecting the lawfulness of processing carried out before withdrawal.
10. How long we keep your information
We retain information for no longer than is necessary for the purposes for which it is processed. Certain periods are enforced by the system automatically. Others are governed by Croydon Drop In’s retention schedule. The table distinguishes between the two.
| Information | Retention period | Automatic |
|---|---|---|
| On-site sign-in and sign-out records, individual movements | 90 days, after which they are aggregated into a daily total and deleted | Yes, nightly |
| Daily totals of time on site | 6 months | No. The total is produced automatically; nothing deletes it automatically. |
| A remembered device for on-site sign-in | 30 days after last use, after which it ceases to function | Yes |
| A reference request link issued to a referee | 21 days, or on submission of the reference, whichever occurs first | Yes |
| Diversity analytics snapshots | Marked to expire two years after production | The expiry date is recorded, but no deletion process currently operates |
| Your profile and account | Until deleted by you, or by us under the retention schedule | No |
| Applications from candidates not appointed | 12 months from submission | Yes, nightly |
| Applications from candidates who were appointed | Retained for the duration of your employment and for 3 years after it ends, as part of your employment record | No |
| Interview notes, scores and offer records | 12 months | No |
| Pre-employment clearance evidence, including DBS details | Retained for the duration of your employment and for 3 years after it ends | No |
| Staff records | 3 years after employment ends | No |
| Security logs and records of administrative actions | 6 months | No. These records cannot be amended or deleted while they are held. |
| Equality monitoring answers | Retained indefinitely. They identify no individual once the associated application has been deleted. | They cannot be amended or deleted |
Periods not yet set
Where the table states that no period is currently set, none has been set. Croydon Drop In’s retention schedule is under review, and this notice will be reissued when those periods are agreed. We have not stated a period that is not enforced, since we could not substantiate it on request.
11. Security
We have implemented appropriate technical and organisational measures to protect your information, including the following.
- Information is transmitted over an encrypted connection, and is encrypted at rest in the database.
- Access is granted by permission, and each member of staff holds only the permissions required by their role. Every change to a person’s permissions is recorded permanently, together with the identity of the person who made it.
- Access controls are enforced in the database itself and not only in the user interface. A person circumventing the interface would still be refused by the database.
- CVs and clearance documents are held in private storage and are accessible only by means of short-lived links.
- Sessions expire after a period of inactivity, and the user is warned before expiry.
- Sign-ins, failed sign-in attempts and administrative actions are logged, and those logs cannot be altered.
In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner within 72 hours of becoming aware of it. Where the breach is likely to result in a high risk to you, we will notify you without undue delay.
12. Your rights
You may exercise the rights set out below free of charge. We will respond within one month. Where a request is complex or where a number of requests have been received, we may extend that period by up to two further months, and will inform you within the first month if we do so. We may ask you to verify your identity before responding.
12.1 Right of access, and to data portability
If you are signed in, you may obtain a copy of your information from Settings by selecting Export my data. The file is produced immediately and contains your account, your profile, your education, employment, courses and referees, and your applications, interviews and offers. It is provided in a structured, commonly used and machine-readable format, which also gives effect to your right to data portability under Article 20.
The export does not include your equality monitoring answers, to which neither you nor the export has access. To obtain those, or anything else not covered by the export, you may make a request using our data request form. An account is not required in order to use the form, and it may be used by a person acting on your behalf.
12.2 Right to rectification
Most information may be corrected by you directly, by editing your profile or your staff record. Where information is inaccurate and cannot be edited by you, such as a note recorded by another person, please email enquiries@croydondropin.org.uk stating what is inaccurate and what it should say.
12.3 Right to erasure, and deletion of your account
If you are signed in, you may delete your account from Settings by selecting Delete account. Confirmation in writing is required before deletion proceeds. The effect of deletion is set out below, since not all information is erased.
Deleted in full:
- Your profile and its contents: education, employment, courses and referees.
- Your uploaded CV.
- Any application commenced but not submitted. A draft has not been read and no decision has been taken on it, so there is nothing to be accounted for.
- Your draft equality monitoring answers.
- Your staff profile and profile photograph, where applicable.
Retained, with your name and contact details removed:
- Applications you have submitted, together with any associated interviews and offers. Submission is what makes an application a record: from that point it may be acted upon, and the basis on which it was decided must remain capable of being accounted for. Your first name, last name and email address are replaced, and the free text you provided is removed, including your supporting statement, your explanation of any employment gaps, your account of any dismissal, your description of other experience, anything written in relation to a criminal record, and any adjustments requested. The fact that an application was made, that a declaration was given, and how the application was determined, is retained.
- Your account record, with the display name and email address replaced.
Retained unchanged:
- Any equality monitoring answers given. These are retained, and the reference linking them to your application is removed when that application is deleted, after which they cannot be identified as yours. See section 4.3.
- Security logs and records of administrative actions. These identify accounts by internal reference rather than by name.
Before you confirm deletion, the system states how many applications, interviews and offers are held, so that the effect is known in advance, and confirms that equality monitoring answers are retained and cease to be linked to you when the application is deleted. The deletion is itself recorded, including any information that could not be removed.
On-site sign-in records are deliberately not linked to your account by a database reference, so that deletion of an account is not prevented by the register. Those records expire on the 90-day cycle described in section 10.
12.4 Right to object, and to restriction of processing
Where we rely on legitimate interests, you may object under Article 21, and we must cease processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms. You may also request that processing be restricted under Article 18 while a dispute as to accuracy, or an objection, is resolved. Please email enquiries@croydondropin.org.uk.
12.5 Right to withdraw consent
We rely on consent for two purposes only: equality monitoring and non-essential cookies. You may amend or clear the monitoring answers saved against your profile, and change your cookie preferences, at any time. Answers given with a submitted application may be withdrawn while that application is retained, but not afterwards, since at that point nothing links them to you (section 4.3). Withdrawal does not affect the lawfulness of processing carried out before withdrawal, and has no bearing on your application.
14. Automated decision-making
No decision concerning your application is taken by automated means. There is no scoring algorithm, no automated filtering and no profiling within the meaning of Article 22. Applications are read and decisions are taken by individuals. The only determination the system makes on its own is the employment gap prompt described in section 3.4, which identifies a matter for enquiry rather than producing a decision.
15. Applicants under 18
Some of those who apply to us are young, and some are applying for their first post. If you are under 18 and would like assistance in understanding this notice, or in exercising any of the rights in section 12, we will explain it in whatever form is most useful to you. A parent, carer or supporter may contact us on your behalf, and you may also contact us directly.
You must be at least 16 to register an account and apply through Unity. We do not require the consent of a parent or guardian for you to apply for a post or to be employed by us, and the rights in section 12 are yours to exercise directly.
16. Changes to this notice
Where we change this notice, we update the version number and date shown at the top. Where a change affects your rights, or introduces a new purpose for which your information is processed, we will notify you by email rather than relying on your noticing the change.
17. Contact and complaints
If you have a concern about how we have handled your information, please raise it with us in the first instance. Email enquiries@croydondropin.org.uk, or write to Croydon Drop In, 132 Church Street, Croydon, London CR0 1RF, setting out what has occurred and the outcome you are seeking.
Complaints to the Information Commissioner
You have the right to complain to the Information Commissioner’s Office at any time. You are not required to raise the matter with us first, although doing so is usually quicker.
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone: 0303 123 1113. Website: ico.org.uk