About this privacy notice
This privacy notice applies to all applicants for employment (whether permanent or temporary) with Aflac Northern Ireland Ltd (NI656209), hereafter referred to as “Aflac NI”, or “we”, “us”, “our”. It sets out the basis upon which we collect, use, store, share and keep secure the personal data provided to us in connection with your application for a position with Aflac NI. The term “job applicant” or “you,” means applicants who apply for, or are in the process of being considered for, employment with Aflac NI.
The Controller
Aflac NI is the “controller" of personal data. We are located at:
Aflac Northern Ireland
City Quays 3
92 Donegall Quay
Belfast, Northern Ireland
BT1 3FE
As the controller, we are responsible for deciding how we hold and use personal data about you. You are being provided with a copy of this privacy notice because you are applying for work with us (whether as an employee, worker, or contractor).
Purpose of this privacy notice
This notice makes you aware of how and why we collect and process personal data for recruitment purposes. It provides you with certain information under the General Data Protection Regulation ((UK) 2016/679) (the GDPR).
This privacy notice also sets out details of how to contact us if you have any questions or comments, or if you would like to exercise any of your rights with respect to personal data about you.
Collecting your personal data
As part of your application, we may collect the information outlined in this privacy notice. Included below are also our reasons and lawful bases for collecting that information.
If you do not provide information that 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.
Candidates who visit our offices for an interview should note that we process personal information recorded on CCTV.
We will typically collect personal data about you either directly (for example, when you call us or send us an email, or when you send us your CV), or through your interaction with our information technology resources. We may also collect personal data about you from third parties (that is, individuals and organizations that are not part of Aflac NI). These third parties may include recruiting agencies and online recruiting platforms and referees. In addition, we may obtain it from some public sources, such as publicly available directories and online resources (for example, information which is publicly available on social media profiles or other external sources).
Information We Collect
Purpose for Collection
Lawful Basis
From initial applicants, we collect name, address, telephone number, Social Security or National Insurance Number(s) depending on your status or other government identification, email address, and employment and educational history.
This data is necessary to determine whether to extend an offer of employment. This data is also necessary to comply with our legal obligations.
Necessary in order to take steps prior to entering into an employment contract; legitimate interest to appoint appropriately qualified and suitable candidates.
Compliance with legal obligations if we are required by Court order to supply your personal data to police as part of any investigations.
For those applicants that are invited to interview with us, we may collect personal details as necessary for us to arrange travel to interview or assessment day. This would include passport numbers and details contained in passports (such as your nationality) or in the alternative national identity card information (if we are to book flights for you and depending upon which documents you use for travel). This is in addition to the information set out in the row directly above – we would use that same information to book your travel.
To book your travel.
Necessary for our legitimate interest in enabling you to attend the interview or assessment day.
For those applicants that receive a conditional offer, we may contact your referees (the person who will provide a reference for you).
This data is necessary to determine whether to confirm an employment offer.
We do this for our legitimate interest of being able to convert your conditional offer into a full offer of employment in order that you may join us.
For those applicants that receive a conditional offer, we will collect passport information or a copy of the applicant’s birth certificate together with an official document giving the person’s permanent National Insurance number and their name issued by a government agency or a previous employer (if the applicant does not possess a passport) (this is relevant for all staff to determine their right to work in the UK)
This data is necessary to determine whether to confirm an employment offer.
Compliance with legal obligations.
If you have a condition that requires accommodation (e.g., food allergies, visual impartment), we may request sufficient details to allow us to accommodate that condition.
This so-called “Special Category” data is necessary in order for use to accommodate the condition and ensure an equitable opportunity at employment with us.
Consent.
We may collect personal data provided by you in relation to your ethnicity, religious beliefs, and sexual orientation.
This information is not compulsory nor can it be. The information is not stored on the applicant’s record.
This so-called Special Category data helps us ensure equal opportunity.
Please note that this information will be held separately to your application and cannot be accessed by those responsible for evaluating your application.
Consent (where necessary).
In all other cases:
Legitimate interests of assessing whether we are attracting candidates in line with our diversity inclusion policies.
Compliance with legal obligations (For some of our processing of special categories of personal data such as about your health or disability access needs our legal obligations may make this lawful without your consent).
Community background/gender
This information is not compulsory nor can it be. The information is not stored on the applicant’s record.
If you voluntarily provide this to us, we will process it on the basis that it is necessary to comply with legal obligations.
It is necessary to comply with legal obligations under fair employment legislation (Fair Employment and Treatment (NI) Order 1998 (“FETO”).
More information about consent
We do not need your consent if we use special categories of your personal data in accordance with this privacy notice if that information is required to allow us to comply with our statutory obligations or if it is for the other lawful reasons.
In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive personal data (or to use personal data in another way as described in this privacy notice). If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us, but we will not be able to process your application further if we seek a consent and if that is refused. You are free not to give that consent or to proceed with your application.
Security
We have appropriate measures in place to prevent personal data from being accidentally lost, used, or accessed in an unauthorized way. We limit access to personal data to those who have a business need for such access. Those individuals who process personal data on our behalf, may do so only in an authorized manner. They are also subject to a duty of confidentiality. We have policies in place that regulate how employees within Aflac NI must handle data, including personal data about you. We limit access to our premises and to our computer networks and take reasonable steps to safeguard against unauthorized access to such premises and networks. We have procedures in place to manage any suspected data security breach and, where required to do so by the applicable data protection/privacy laws, will notify you and/or any applicable regulator of a suspected data security breach consistent with the relevant legal requirements
Sharing your personal data
As part of the application and on-boarding process, we may transfer personal data about you to Aflac US in the United States. We do this for our legitimate interests of being able to find appropriately qualified and suitable candidates and improve HR administration (for example, to help make management decisions regarding employment, engagement, and related processes). We also do this for our legitimate interests and those of Aflac US which has its group wide overall business operations (for example, to enable compliance with applicable laws and regulations which apply to Aflac US).
When we do transfer personal data, we will use an appropriate legal mechanism, including the International Data Transfer Agreement for transfers from the UK to the US.
We may transfer personal data about you to third parties in accordance with this privacy notice. Some will be processing that personal data on our behalf. Some will be processing it as independent data controllers and, in those cases, we must ensure lawful reasons under GDPR to facilitate the transfer. We will ensure that we have a lawful basis for doing so as may be required under applicable law with respect to that transfer, including legitimate interest under the GDPR.
The broad classes of third-parties to which we may transfer personal data about you pursuant to our legitimate interests (this is relevant when the recipients are independent data controllers) include: recruiting agencies and online recruiting services, immigration and travel agents; relocation consultants; companies that we provide services to, in circumstances where you are involved in such services; financial services providers who provide a financial service to you; accountants; lawyers; the organisation providing us with a recruitment platform which we use to track candidates as they move through our recruitment process, and HR, benefits and compensation consultants. We also transfer some personal data about you to governmental authorities (including tax authorities) where required by, or in order to comply with, law.
We will endeavour to ensure that all non-governmental third parties to which we transfer personal data about you agree, as part of their contract with us, to treat personal data about you in accordance applicable data protection/privacy laws.
Note that where we have a relationship with another controller (particularly when we use a third-party recruiting agency or online recruiting platform), any personal data provided as part of your job application with Aflac NI will also be processed by them (and potentially their own third-party providers).
We may disclose personal information if required to do so by law (e.g., to HMRC, the police, the Information Commissioner’s Office, courts of law) or if we believe that such action is necessary to protect and defend the rights, property or personal safety of Aflac NI, its employees, staff, agency workers and customers of our Services.
From time to time, we may also be required to provide your personal data with other persons, such as in the event that we sell any business or assets (in which case we may disclose your personal data to the prospective buyer of such business or assets) or if we, or substantially all of our assets, are acquired by a third party (in which case personal data held by us about you will be one of the transferred assets) or if we are required to disclose your personal data in connection with any legal proceedings or requirements (such as to our lawyers, government agencies, courts or tribunals).
Retaining your personal data
If you are successful in your job application, we will continue to hold the personal data you provided during the recruitment process, and you will be issued with the employee privacy notice.
If you are unsuccessful, we will retain your personal data for a period of up to twelve months after we have communicated to you our decision about whether to appoint you to the role you for which you have applied. We retain your personal data 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. In addition, we retain it for this period in case of queries from you (for instance you might ask us for feedback about why your application/interview was not successful in relation to the role). After this period, we will securely destroy your personal data in accordance with applicable laws and regulations (unless required to retain it to deal with any legal claim).
You have the right to withdraw your consent at any time. To do this please use our contact details (below).
Anonymized fair employment monitoring information will still be retained to allow Aflac NI to comply with applicable statutory and regulatory obligations.
Retention of CCTV images. We apply a separate criteria to retention of these records, as follows. We retain CCTV images for 30 days (unless they are needed because of a dispute between us or because of a police investigation) and after that they will be erased because we will not need to retain them for any security of premises reason (which is why we have CCTV).
Your rights
You are entitled to certain rights, which are briefly summarized below, in relation to any personal data about you which we hold.
We will comply with your exercise of rights where applicable law requires, although we may choose to offer these rights, even if we are not required to do so.
The right to be informed about your processing of your personal information;
The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
The right to object to processing of your personal information;
The right to restrict processing of your personal information;
The right to have your personal information erased (the “right to be forgotten”);
The right to request access to your personal information and to obtain information about how we process it;
The right to move, copy or transfer your personal information (“data portability”);
Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.
Where our processing of personal data about you is based on your consent, depending on the applicable data protection/privacy law which applies, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing personal data about you for that purpose, unless we have some other lawful basis to continue that processing (e.g., to comply with a legal or regulatory obligation). Your withdrawal of your consent will not impact any of our processing up to that point.
For more information on your rights and how to use them, or if you would like to exercise any of your rights, please contact us using the details set out in the section “How to contact us.” There are certain circumstances in which the rights described in this section will not apply, and we will draw that to your attention if you make a request to exercise such a right.
Without prejudice to any other administrative or judicial remedy you might have, you may have the right to lodge a complaint with local state regulators/data protection authorities if you believe that we have infringed applicable privacy or data protection requirements when processing personal data about you. In the UK, you may contact:
The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 1625 545 700
email: casework@ico.org.uk
Website: https://ico.org.uk
How to contact us
You can get in contact with us via email on ani-privacy@aflac.com or by writing to us c/o Aflac Northern Ireland, Privacy Office, City Quays 3, Donegall Quay, Belfast BT1 3FE.
We have appointed the Aflac NI Privacy Representative to be responsible for our approach to data protection and protecting your privacy. For any queries you have in relation to this privacy notice and the use of your personal data, you can contact them through ani-privacy@aflac.com.
The Information Commissioner’s Office (ICO) is the UK supervisory authority for data protection issues. If you are unsatisfied with our response to any data protection issues you raise with us or the Aflac NI Privacy Representative, you have the right to make a complaint to ICO. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.