As part of any recruitment process, Starling Bank collects and processes personal data relating to job applicants. Starling Bank is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
This Privacy Notice applies to all job applicants and potential candidates for employment with Starling Bank.
For the purposes of the data protection laws, the data controller is Starling Bank Limited company number 09092149 and we have our registered office at 5th Floor, London Fruit and Wool Exchange, 1 Duval Square, London, E1 6PW.
What information does Starling Bank collect?
Starling Bank collects a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- information about your entitlement to work in the UK.
In addition, where relevant, we may also use, share and retain data classified as ‘special or sensitive category’ data in accordance with data protection law. This includes:
- whether or not you have a disability for which Starling Bank needs to make reasonable adjustments during the recruitment process;
- information from criminal record checks
Starling Bank collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
Starling Bank will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. Starling Bank will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does Starling Bank process personal data?
Starling Bank needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, Starling Bank needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
Starling Bank 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 Starling Bank to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. Starling Bank may also need to process data from job applicants to respond to and defend against legal claims.
Where Starling Bank relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of job applicants, employees or workers and has concluded that they are not.
Starling Bank processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
For some roles, Starling Bank is obliged to seek information about criminal convictions and offences. Where Starling Bank seeks this information, it does so because it is necessary for it to comply with a regulatory requirement to establish whether or not an individual has committed an unlawful act or been involved in dishonesty or other improper conduct.
Who has access to data?
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
Starling Bank will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Starling Bank will then share your name, email address, phone number and CV with our employment background check provider to obtain necessary pre-employment screening checks.
How does Starling Bank protect data?
Starling Bank takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.
For how long does Starling Bank keep data?
If your application for employment is unsuccessful, Starling Bank will hold your data on file for 12 months. At the end of that period, your data is deleted or destroyed.
If your application for employment is successful and you choose to accept the role with Starling, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in the staff privacy notice.
Your rights
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require Starling Bank to change incorrect or incomplete data;
- request that Starling Bank deletes your information and we will do so, but only if we do not need to lawfully retain it for any other purpose; and;
- restrict or object to the processing of your data, providing that Starling Bank does not have any legitimate grounds which overrides this;
- obtain human intervention and not be subject to a decision based solely on automated processing.
If you would like to exercise any of these rights, please contact privacy@starlingbank.com. Starling Bank will then aim to facilitate your request within 1 calendar month.
If you believe that Starling Bank has not complied with your data protection rights, you may refer your complaint to the UK’s supervisory authority; the Information Commissioner’s Office (ICO).
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to Starling Bank during the recruitment process. However, if you do not provide the information, Starling Bank may not be able to process your application properly or at all. If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the UK and satisfactory references. If you fail to provide certain personal information as part of our pre-employment screening, then we may be required to rescind your conditional employment offer.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.
This privacy notice is effective from March 2022.