Effective Date: 06/05/21
Alternative Payments Ltd (also known and trading as Judopay) is registered in the United Kingdom under Company Number 07959933, with its registered address at Rise London, 41 Luke Street, London, United Kingdom, EC2A 4DP (“Judopay”,“we”, “us”, “our”).
Alternative Payments Ltd is registered with the UK Information Commissioner’s Office (ICO) under number ZA080409.
In accordance with the General Data Protection Regulation (“GDPR”), we have implemented this privacy notice (“Privacy Notice”) to inform you, as prospective employees, consultants our contractors of Judopay, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
Judopay is a controller in relation to personal data. This means that we are responsible for deciding 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 or contractor). 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 GDPR.
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
We keep several categories of personal data on our prospective employees in order to carry out effective and efficient processes. We keep this data in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example, recruitment logs.
Specifically, we hold the following types of data:
You provide several pieces of data to us directly during the recruitment exercise.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies or carrying out background checks.
Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins.
The law on data protection allows us to process your data for certain reasons only.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
We will use the personal information we collect about you to:
It is in our legitimate interests to decide whether to appoint you to the 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 any form of contract with you.
Having received your CV and covering letter or your application form (as applicable), 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 work. If we decide to offer you the role, we will then take up references and/or carry out a criminal record and/or carry out any other check before confirming your appointment.
If you fail to provide personal information or 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.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
Information about criminal convictions
We envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the role conditional on checks and any other conditions, such as references, being satisfactory. We are required to carry out a criminal record check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular, we are legally required by regulation to carry out criminal record checks for those carrying out work for Judopay. Our standard approach to conducting criminal record checks will be to ask you to seek a basic disclosure of your criminal records history, a high degree of trust and integrity required to perform work at Judopay.
In some cases, the role may be one which is listed on the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (SI 1975/1023) and is also specified in the Police Act 1997 (Criminal Records) Regulations (SI 2002/233), so is eligible for a standard or an enhanced check from the Disclosure and Barring Service.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
Employees within our company who have responsibility for recruitment will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processed in line with GDPR.
Data is shared with third parties for the following reasons:
We may also share your data with third parties as part of company sale or restructure, or for other reasons to comply with a legal obligation upon us. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We may share your data with companies outside of the European Economic Area. We will make sure that appropriate measures are in place to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred process it in a way required by EU and UK data protection laws.
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. 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. Details of these measures may be obtained from our Head of IT Security at firstname.lastname@example.org.
Additionally, 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.
We only keep your data for as long as we need it for, which, in relation to unsuccessful candidates, is six months to a year. If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for the maximum of one month once the recruitment exercise ends.
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 in accordance with our data retention policy or applicable laws and regulations.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for nine months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
Automated decision-making means making decision about you using no human involvement e.g. using computerised filtering equipment. No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
You have the following rights in relation to the personal data we hold on you:
In addition to the above rights, you also have the unrestricted right to withdraw consent, that you have previously provided, to our processing of your data at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact our Data Privacy Manager.
If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745. We do however ask that you contact the Judopay Privacy team in the first instance, details below.
In respect of our data protection activities, you may contact:
Data Privacy Manager
Alternative Payments Limited
Address: Rise London, 41 Luke Street,London, United Kingdom, EC2A 4DP
Tel: +44 (0) 203 503 0600