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Background Checks

Background Checks – Privacy Notice

  1. Introduction: We are Gazeley (part of the GLP group).  Gazeley is represented for the purposes of this notice by GLP UK Management Limited. Our company number is 11065864 and our registered office is at 50 New Bond Street, London, W1S 1BJ. All references in this policy to “Gazeley”, “our”, “us” or “we” refer to GLP UK Management Limited.
  2. What this notice is for:  This notice applies to individuals that we have asked to take part in background screening checks. These checks are requested by us where the nature of the services involve sensitive matters or certain regulated activities.This notice only relates to our use of personal information to carry out background checks. To find out more general information about how we use your personal data for other purposes, and how to contact us, please see our Privacy Policy.
  3. Personal information provided by you: You may be asked to provide us with the following documents:
    1. your passport (containing your name, date of birth, passport number, address and photograph); and
    2. your driver’s licence (containing your name, date of birth, address and licence number).
  4. Personal information obtained by third parties on our behalf: We use third party service providers, in particular, Sterling Talent Solutions UK Limited (“Sterling”), to carry out background checks on our behalf. These service providers will often obtain relevant personal information about you from external sources, including public records; law enforcement or other government agencies; court information aggregators; former employees; and credit / consumer reporting agencies.The following personal information about you will be obtained by third parties on our behalf:
    1. address history and travel history;
    2. credit or bankruptcy history, and civil court records;
    3. employment history, education history, volunteering history, professional credentials, designations, memberships, sanctions or reprimands; and
    4. other public record information.
  5. What we use your personal information for: We, or third parties on our behalf, use your personal information to carry out background checks and credit history searches. In particular, the following background checks are performed:
    1. education history verification;
    2. credential verification;
    3. credit enquiry (UK) searches;
    4. activity and gap verification; and
    5. CV discrepancy check.We will use the results of the above background checks to inform our decision on whether to engage your employer as one of our suppliers.We currently use Sterling to perform these checks. Further information on how these checks are carried out and what they entail may be found in the Sterling Privacy Statement.
  6. Legal basis for use of your personal information:
    1. Consent:
      1. We (or Sterling on our behalf) will only process your personal information in order to perform background checks, as described in this notice, on the basis of your written consent. You may refuse to provide your consent by not completing the applicable consent form.
      2. If we and/or Sterling rely on your consent to use your personal information to perform background checks, as described above, but you later change your mind, you may withdraw your consent at any time by contacting us at contact@gazeley.com and we will stop doing so (and will ensure that Sterling stops using your personal information in this way).
      3. Please note that withdrawing your consent after giving it will not affect the lawfulness of any processing based on consent before its withdrawal, which will include any background checks already performed.
    2. Legitimate interests:
      1. We will retain the report summarising the results of your background checks, which Sterling provides to us, where necessary for our legitimate interests. Our legitimate interests are to prove to third parties (in the event of an investigation or audit) that we have used appropriately skilled and qualified suppliers in accordance with our regulatory obligations.
      2. When relying on our legitimate interests for using your personal information, we will undertake a balancing test to ensure that our legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.  You can ask us for information on this balancing test by emailing us at contact@gazeley.com.
  7. How and why your personal information is shared: We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes, such as compliance, auditing and monitoring.We will also disclose your personal information to service providers, such as Sterling, who carry out background checks on our behalf. While carrying out these background checks, such service providers may need to provide your personal information to the third party sources referenced at paragraph 4.1 and to certain sub-contractors engaged to perform specialised tasks. Use of such sub-contractors will depend on the nature of the checks, but can include: cloud storage and IT support services, court runners and translation services. In relation to Sterling, further information on when your personal information may be shared with others is set out in the Sterling Privacy Statement.Background check providers, such as Sterling, will also share some of your personal information with us when they provide the results of the relevant checks. Sterling is prohibited from using your personal information for any purpose other than to perform background checks for us.
  8. Overseas transfers and how we protect your information: Your personal information may be used, stored and/or accessed by third parties operating outside the European Economic Area. The countries that we may transfer your information to, and the measures used to ensure your information is protected, are described in section 5 of our Privacy Policy and those that Sterling may transfer them to are set out in the Sterling Privacy Statement. Further details are also available from us on request by contacting us at contact@gazeley.com.
  9. Automated decision-making: We, and third parties processing your data on our behalf, do not use your personal information to make automated decisions about you without any human involvement.
  10. How long we store your personal information: We will only keep the personal information contained in the summary report provided to us by Sterling for a period of 7 years from the date on which your employer is engaged to provide services to us. Otherwise, after completing the above background checks, we will delete your personal information (and instruct any third parties processing your personal information on our behalf to do the same). If you or your employer are not engaged to provide services, we will immediately delete any personal information that we hold about you.
  11. Exercising your rights: You have certain rights in relation to your personal information, including (in some circumstances) rights of access, rectification, erasure, restriction, objection and portability. If you would like further information on what these rights involve, or would like to exercise any of them, please see section 7 of our Privacy Policy.
  12. Further questions and how to make a complaint: If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please refer to our Privacy Policy or contact contact@gazeley.com.

You may also make a complaint to the Information Commissioner’s Office.  Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

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