Who we are and what we do
We are “Publica Group Limited” and are a council owned employment company which delivers shared services between Cotswold, West Oxfordshire, and Forest of Dean District Councils and Cheltenham Borough Council (hereon known as “Clients”. Publica additionally provides services to the Cheltenham Trust, Cheltenham Borough Homes and UBICO (an environmental services local authority company) (heron known as “Clients”).
Our Human Resources (HR) service needs certain information to progress your application to work and to fulfil our and our clients’ legal obligations as an employer.
Publica is a Data Controller and Data Processor for the purposes of the Data Protection Legislation (UK General Data Protection Regulation and the Data Protection Act 2018).
Any questions regarding our privacy practices should be sent to:
Data Protection Officer (DPO)
Trinity Road, Cirencester¸ GL7 1PX
Tel: 01993 861194
Why we need your information and how we use it
When you apply for a role with us or our clients, we provide our services, we ask for personal information for recruitment purposes, to allow us to carry out pre-employment checks. We are required to process your information as an employer under the following legislation:
- Employment Rights Act 1996
- Employment Act 1992
- The Rehabilitation of Offenders Act 1974
- Equality Act 2010
- Enterprise and Regulatory Reform Act 2013
- Trade Union Act 2016
For recruitment purposes, the information that you submit electronically is held and processed by our dedicated recruitment software. The recruitment software forms part our recruitment process and is data processor for Publica. Our recruitment software will not share your information with any third parties outside of our agreements. By entering your application information into our recruitment software you are permitting Publica to access and use your information for our specific recruitment process.
Your data will be saved periodically before you reach the end of the application form. This is to help you if you want to complete the form over a number of visits and to limit data loss as a result of a technical issue, such as an accidental browser closure or a loss of internet connection. Our recruitment software will store your details for a retention period of 7 years, but for unsuccessful candidates we will only keep your records for 12 months. Your personal information will be deleted automatically once the data retention period is reached.
Your application and documentation will be kept on file, securely, for 12 months. Your job account will remain active for an additional 12 months from the date of your last job application unless you advise the Publica otherwise. If you decide that your data is to be removed from the system please e-mail firstname.lastname@example.org
Should you wish to remove your details prior to automatic deletion, please contact Publica Human Resources directly.
Publica collects personal data about you from third parties, such as references supplied by former employers, information from employment background check providers, information from credit reference agencies and information from criminal records checks permitted by law.
Data is stored in a range of different places, including in your personnel file, in Publica's HR management systems (including recruitment software) and in other IT systems (including Publica's email system).
What is the legal process for collecting and processing this data
Publica or one of our clients has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.
What type of information is collected from you
If you are applying for a role (with Publica, or our clients), you will be provided with login details to our recruitment software and or have been selected as a preferred candidate or employee.
We would ask for your name, address, date of birth, contact details, national insurance number (only where you have been made an offer), proof of identity, your education and employment history, professional registration and/or qualifications, whether you have a criminal record (only "unspent" current convictions) or have disclosure and barring service checks (where the role involves working or access data relating to children, vulnerable adults or patients), disability and health information and bank account details (only if you are successful for salary purposes).
We may process special categories of data, such as equality data (for example race, disability, sexual orientation, gender religion, marital status) to monitor recruitment statistics, enable the partner Councils (including Publica) to manage its legal requirements under the Equality Act 2010 (Public Sector Equality Duty) and inform discussions about how to improve diversity. This requires the partner Councils (including Publica) to understand and act on how different equality groups are able to access different opportunities and to carry out a fair recruitment process. It will not be used in any way which allows any individual to be identified.
Who your information may be shared with (internally and externally)
If you become an employee of Publica or one of our clients that we provide a payroll service to, your personal details such as your name, address, National Insurance number, salary and bank account details will be provided to our Payroll service and HMRC for salary and tax purposes. If you opt in to your Employer Pension schemes, your details will also be held by the Pensions teams with our thirds party providers.
In addition, we share information with the following:
- National Fraud Initiative: The Council has a legal duty to submit information to the government as part of the National Fraud Initiative. The National Fraud Initiative matches electronic data within and between public and private sector bodies to prevent and detect fraud. These bodies include police authorities, local probation boards, fire and rescue authorities, local councils and a number of private sector bodies.
- Occupational Health: The Council operates an Occupational Health Scheme. Where employees agree to be referred to Occupational Health, we will share personal information with the Occupational Health service provider that may include information relating to
- Third parties: Sometimes we will pass information about you to third parties where the law allows it. For example, we may provide personal information to a prospective employer or to your pension provider if you join a pension scheme. Where another party is responsible for part or all of your employment, we will share personal information about you to the other party.
- Register of Interests: Section 117 of the local Government Act 1972 states that we will share personal information to any relevant officers and councillors to make known details of the interest held by you that may be relevant to Council business.
In all cases, we will only share your personal data where it is lawful to do so and where we are satisfied that appropriate security measures are in place to keep your personal data safe and secure and processed only in accordance with the General Data Protection Regulation (GDPR) and Data Protection Act 2018.
How long we keep your information (retention period)
If you are applying for a role and are unsuccessful, we will keep your data for 12 months, after which time it will be destroyed if you so wish. If you decide that your data is to be removed from the system please e-mail email@example.com
If you become an employee of Publica or one of our clients, we will keep your data for a minimum of 6 years after the end of your employment after which time it will be destroyed. More information on our corporate retention schedule can be found online
How we protect your Information
We will not transfer your personal data outside the EU without your consent.
We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
For any payments which we take from you online we will use a recognised online secure payment system. We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
You have rights under the Data Protection Legislations:
to access your personal data
to be provided with information about how your personal data is processed
to have your personal data corrected
to have your personal data erased in certain circumstances
to object to or restrict how your personal data is processed
to have your personal data transferred to yourself or to another business in certain circumstances
to be told if we have made a mistake whilst processing your data and we will self report breaches to the Commissioner
How you can access, update or correct your information
The Data Protection Legislation allows you to find out what information is held about you, on paper and computer records. This is known as ‘right of subject access’ and applies to your Human Resources data along with all other personal records.
If you wish to see a copy of your records you should contact the Data Protection Officer (firstname.lastname@example.org). You are entitled to receive a copy of our records free of charge, within a month.
In certain circumstances, access to your records may be limited, for example, if the records you have asked for contain information relating to another person.
The accuracy of your information is important to us to be able to provide relevant services more quickly. We are working to make our record keeping more efficient. In the meantime, if you change your address or email address, or if any of your circumstances change or any of the other information we hold is inaccurate or out of date please email us or write to us at:
Publica Group Limited
Trinity Road, Cirencester¸ GL7 1PX
Tel: 01993 861194
If you would like to know more about how we use your information, or if for any reason you do not wish to have your information used in any of the ways described in this leaflet, please tell us. Contact the Data Protection Officer.
You can also complain to the Information Commissioner: https://ico.org.uk