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Recruitment privacy policy

How to use this privacy notice

This privacy policy will allow you to better understand how the personal information you supply The Pensions Regulator (TPR) is held and processed as part of the application, recruitment and onboarding process with us.

This privacy policy covers recruitment of the following types:

  • permanent vacancies
  • fixed-term vacancies including professional placements
  • contingent labour including temporary workers and contractors
  • internal and external secondments and loans
  • apprenticeships
  • work experience
  • professional placements

You will see the following details:

  • the specific personal information held and used
  • our purpose for using the information
  • our legal basis for using the information
  • any information we obtain from other sources
  • who we share the information with and the reason for this
  • how long we will retain your personal data for
  • your rights over your personal data
  • when we intend to transfer to another country
  • cookies

TPR is the data controller. You can email TPR in its capacity as data controller at: dpa@tpr.gov.uk.

You can email TPR’s Data Protection Officer (DPO) directly at: dpo@tpr.gov.uk.

Alternatively, you can write to the DPO using the address below:

Data Protection Officer

The Pensions Regulator

Telecom House

125-135 Preston Road

Brighton

BN1 6AF

The specific personal information held and used

The personal information we will collect and use as part of the application process is:

  • title
  • name
  • address
  • telephone numbers
  • personal and/or work email address
  • work history
  • education
  • any reasonable adjustments
  • disability declaration
  • your pronouns
  • notice period

As a disability confident employer, we’re committed to the recruitment and employment of people with disabilities, and to improving their employment opportunities. Candidates who declare that they have a disability and who meet the essential criteria for the job will be offered an interview. This information will be held and used only for the application and interview process.

During the application process you have the option of providing special category data, for the purposes of Equality, Diversity and Inclusion monitoring, (you can select ‘prefer not to say’ for all these categories):

  • ethnicity
  • disability
  • gender identity
  • religious belief
  • sex
  • sexual orientation
  • unpaid caring responsibilities

During the interview stage of the application process, the following data may, where necessary, be collected:

  • driving licence
  • passport
  • birth certificate
  • proof of current address (such as bank statements and council tax bills)
  • evidence of your right to work in the UK and immigration status
  • record of correspondence if you contact us regarding your application
  • status of your application and updates
  • interview data including, but not limited to, interview notes, recordings, presentations, tasks and assessments, assessment centres, testing, and shortlisting
  • some roles require you to take an online assessment/test

If we make a conditional offer of employment, we will ask you for information so that we can carry out pre-employment checks and health questionnaire such as:

  • full name
  • current address
  • address history over a 5-year period
  • date of birth
  • proof of identity
  • right to work documents and share code
  • proof of your qualifications
  • criminal record declaration
  • employment and activity history, including references

Some roles, such as board director appointment, will require a higher level of security clearance and, if this is the case, we will advise you know should this be required.

As part of the onboarding process, we will also ask for the following information:

  • PAYE checklist
  • bank details to pay in your salary
  • emergency contact details
  • National Insurance number
  • any membership of a Civil Service Pension scheme

Our purpose for processing the information

We will use your information for the following purposes:

  • Process your application.
  • Invite you to interview (if relevant).
  • Referencing, pre-employment checks and onboarding on appointment.
  • Monitor applicant pools for our equality and diversity data (you may prefer not to supply this data).
  • Publish non-identifiable data under our Public Sector Equality Duty.
  • As a Disability Confident Employer, we are committed to the recruitment, employment, retention and development of disabled people. We will offer candidates who declare that they have a disability and who meet the essential criteria for the job an interview.
  • Process your details for alternative job opportunities at TPR. You will be notified if we choose to do this. Data is retained as outlined in the below section (How long we will retain your personal data for).

Please note our recruiting managers shortlist applications for interview.

You must successfully complete pre-employment checks to progress to a final offer. We are legally required to confirm your identity and right to work in the UK.

If you choose to supply equality and diversity data, we will not make this information available to any staff outside our recruitment team (including recruiting managers) in a way that can identify you. Your application will not be affected if you choose not to supply equality and diversity data.

We do not use your personal data for making any automated decisions about you.

Occasionally we may process your personal data for the purpose of detecting and preventing fraud.

Our legal basis for using the information

  • Article 6(1)(b) Contract – where processing is necessary to perform a contract or take steps, at your request, before entering a contract.
  • Article 6(1)(c) Legal obligation – for us to establish and record the right to work, security checks (including criminal convictions), if you provide us with any information about reasonable adjustments so that we can comply with our obligations under the Equality Act 2010. In addition, we rely on the processing condition at Schedule 1 part 2 paragraph 6(2)(a).
  • Article 6(1)(f) Legitimate interests – TPR has a legitimate interest in processing your personal data to administer and consider your application. The risk to data subjects arising from these checks is that if adverse information is discovered during the recruitment process, TPR may not provide or confirm an offer of employment to a candidate. It is in a candidate’s best interest to provide full disclosure during preemployment assurance processes so any risks they present as a potential employee can be properly assessed.

Where we process special category data about you, we rely on the following lawful basis:

  • Article 9(2)(a) Explicit consent – for special category data (e.g. ethnicity, gender, disability) should you choose to supply such information. For example, EDI questions or as part of the disability guarantee scheme.
  • Article 9(2)(f) Legal claims or judicial acts – for the establishment, exercise or defence of legal claims.

Any information we obtain from other sources

Other than the personal information collected from you directly, we also obtain personal information about you from other sources:

  • LinkedIn
  • external job boards
  • pre-employment checks, including references and baseline personnel security standards (BPSS) check on appointment only

BPSS checks will include:

  • five years background and reference checks
  • right to work in the UK
  • Disclosure and Barring Service (DBS)

Who we share the information with

Your data will be shared internally and only with staff and departments that require the use of the data in order to assess your suitability for the job role for which you have applied.

We will not routinely pass your information to any other organisation except where required to do so as part of our functions or by law. Your information may be shared with our partners identified through the below recruitment frameworks working with us to recruit for a TPR role.

TPR engages with recruitment agencies on the following recruitment frameworks:

Pre-employment checks are carried out for us by Giant who carry out pre-employment checks, including the right to work in the UK, background, referencing and DBS checks.

For director roles, Giant will check 10 years of employment history and activity as well as social media, adverse financial and directorship checks.

Social media check – a comprehensive, global check of a candidate’s social media postings. We will identify their social media accounts, flag any content that falls into agreed risk categories. The risk categories they check are any adverse profiles pertaining to present flags:

  • extreme opinions
  • hate or discriminatory language
  • illegal activities
  • inappropriate or undesirable content
  • potential addiction or substance abuse
  • sexually explicit content
  • violent or graphic content

Adverse financial check – they check publicly available data to reveal any adverse information including County Court Judgements, bankruptcies, voluntary arrangements, decrees in Scotland and administration orders. The results will show aliases, linked addresses and adverse information including corrections associated with the individual.

Directorships – a search conducted against Companies House data to indicate if the candidate holds any current/previous directorships or is disqualified.

Any discrepancies or issues with these are flagged to the People Service Team for review.

Recruitment agencies (RM6277 and ESPO 3S-22) – carry out pre-employment checks, including the right to work in the UK, background, referencing and DBS checks for temporary and contract workers.

All new starters will also complete a health declaration at the onboarding stage. The health declaration is to be completed prior to commencement of work. TPR is an equal opportunities employer and recruits based on ability, not perceived disability. We ask about health because if you have a disability of health condition, we need to understand how it could affect your ability to carry out tasks of the job you are applying for. It enables us to consider adjustments we could make to help you take up employment or carry out your tasks efficiently.

We provide information to My Civil Service Pension to enrol you into the Civil Service Pension Scheme.

We provide information to other government and public bodies, if you are moving on external secondment.

Very exceptionally, data supplied by you or by a third party may be sufficiently serious that the TPR may consider it is necessary and in the public interest to share relevant information with an appropriate authority such as the police. This might occur, but is not limited to, when information suggests that:

  • you may have committed a previously undetected criminal offence, or that an offence may be about to be committed
  • you or others may be at risk of harm

We will not share any of the information you provide with any third parties for marketing purposes.

Your rights over your personal information

Equality and diversity data - withdrawal of consent

Consent must be a clear positive and affirmative action that you have given your agreement to the use of your personal information, and consent can also be withdrawn at any point if you are no longer happy with the use of your personal information for a specific reason. If you to wish to withdraw consent, please do so by emailing us at dpa@tpr.gov.uk or the DPO at dpo@tpr.gov.uk.

Once consent is withdrawn, we will destroy all relevant personal information. Withdrawing your consent does not affect the lawfulness of any processing based on consent before you withdrew consent.

Further information on your rights and how to exercise them

Further details on your rights and how to make a request to exercise any of those rights is set out in our privacy notice.

If you have any questions on these please email us at dpa@tpr.gov.uk or the DPO at dpo@tpr.gov.uk.

When we intend to transfer to another country

Your personal information is held on our Applicant Tracking System and will be stored securely within the UK and will not be transferred outside that territory unless required by a court order.

Any contact through emails or calls are held on our Microsoft estate and may be stored securely outside of the UK . In these instances, we rely on either adequacy regulations as set out in article 45 of the UK GDPR.

How long we will retain your personal data for

Information will be kept in line with our retention policy.

Personal data contained within our Applicant Tracking System is redacted after 12 months of an application being submitted. Minimal data, application reference, is retained for reporting purposes. Any special category data is anonymised.

Cookies

Our Applicant Tracking System, hosted by iTrent for customers such as TPR, uses strictly necessary cookies to allow the site to function properly and to enable the successful communication between the end-user and the service. The additional cookies added to our cloud services architecture do not collect personal data or perform any behavioural tracking.

Find information on cookies of other TPR sites.

A link to a more specific privacy notice or information page

Information about the measures that MHR International UK Limited/iTrent and Veritone Hire have in place to keep your information secure can be found at:

MHR UK Privacy Policy, MHR Privacy Statement

Veritone Privacy Policy: Ensuring the Protection of Your Data

Find information about working for TPR.

Further details about how we process the personal information of our employees is provided in a separate employee privacy notice provided when beginning your employment.