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In this privacy notice a reference to “we” is a reference to The OGTC.  References to “you” are references to any individual applicant, 

As part of any recruitment process, The OGTC collects and processes personal data relating to job applicants.  We are committed to being transparent about how we collect and use that personal data and to meeting our data protection obligations.

This privacy notice is issued under and in accordance with applicable data protection laws including, but not limited to, the General Data Protection Regulation (“GDPR”) and applies to all individuals applying for roles with The OGTC, whether as an employee, via any contractor relationship or otherwise.  We require all individuals applying for roles with The OGTC to read and act in accordance with this notice.


The law says that the personal data we hold about you must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for legitimate purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only for as long as is necessary for the purposes we have told you about
  • Kept securely.


Personal data is as defined in the GDPR and means any information about a living individual from which that person can be identified.  It does not include data where the identity has been removed (anonymous data).

The OGTC collects a range of personal data about you including:

  • Personal contact details such as name, title, addresses, contact details (including email address and telephone number(s)
  • Details of your qualifications, skills, experience and employment history
  • Identification documents (including passports and driving licences)
  • Information about your current level of remuneration, including any benefits entitlements
  • Information about your entitlement to work in the UK
  • Photographs

the way we will collect your personal DATA

Your personal data is collected through the application process in different ways, for example, personal data might be contained in CVs, passport or other identity documents or collected through the interviews which are held with you and any other forms of assessment such as online testing.

The OGTC will also collect personal data about you from third parties such as references supplied by former employers or employment agencies.  The OGTC will seek information from third parties only once a job offer has been made to you and we will confirm that we are taking up references.

where we will keep your personal DATA

The personal data we collect will be stored in HR files and systems (including email).

why we process your personal DATA

The OGTC needs to process personal data prior to entering into a contract with you and again if we do enter into a contract with you.

Sometimes we need to process personal data to ensure that we are complying with legal obligations, for example, we are required to check an applicant’s eligibility to work in the UK prior to any employment starting.

We have a legitimate interest in processing personal data during the recruitment process and keeping records of that process. 

By processing personal data from job applicants, we can manage the recruitment processes, assess and confirm your suitability for employment (including your entitlement to work in the UK) and make decisions on job offers.  There are times when we may need to process personal data from job applicants in the response to and defence of any legal claims which may be brought and for the prevention and detection of fraud and other criminal offences.

If you fail to provide certain personal data when requested, we may not be able to progress your application.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


We may also collect and use “special data” of more sensitive personal data (which require a higher level of protection) in the following circumstances:

  • In limited circumstances, with your explicit written consent;
  • Where we need to carry out our legal obligations;
  • Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

In particular, we will use sensitive personal data about your physical or mental health, or disability status, to address any possible obligation or adjustment under the Equality Act 2010 which may arise during the recruitment process.

who has access to your PERSONAL Data

Your personal data will be shared for the purpose of the recruitment exercise, this includes sharing with members of the HR and recruitment team, interviewers involved in the recruitment process, and Managers in the business area with a vacancy.

We will not share your personal data with third parties, until your application for employment is successful and you receive an offer of employment.  We will then share your personal data with third parties where required by law, where it is necessary to administer the application process or where we have another legitimate interest in doing so.  In particular, we may share your personal data with former employers to obtain references for you. 

We require third parties to respect the security of your personal data and to treat it in accordance with the law. 

We do not transfer your personal data to countries outside the European Economic Area (EEA).

Data security

The OGTC takes the security of your personal data very seriously and has internal policies and controls in place to ensure that your personal data is not lost, accidentally destroyed, misused or disclosed and is not accessed except by its employees and third party providers in the legitimate performance of their duties in relation to the recruitment process.

If you are successful in your application for employment, personal data gathered during the recruitment process will be transferred to your personal file and retained in accordance with Company policies.  You will be provided a new Employee Privacy Notice at that time which shall apply from the time you take up employment with, or engaged by, The OGTC.


We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.  Details of the specific retention periods for which your personal data is held are available in our Data Retention and Disposal Policy. 

your Rights

As a data subject, you have several rights, you can:

  • Access and obtain a copy of your personal data on request;
  • Require the organisation to change incorrect or incomplete personal data;
  • Require the organisation to delete or stop processing your personal data where the personal data is no longer necessary for the purposes which it was collected for;
  • Object to the processing of your personal data where we are relying on our legitimate interests as the legal ground for processing;
  • Ask us to stop processing personal data for a period if the personal data is inaccurate or there is a dispute about whether or not your interests override the Company’s legitimate grounds for processing the personal data; and
  • Request the transfer of your personal data to another party.

If you would like to exercise any of these rights please contact the HR Adviser dealing with the vacancy you’ve applied for. 

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.  To withdraw your consent, please contact the HR Adviser dealing with the vacancy you’ve applied for.  Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.


You are responsible for helping The OGTC keep your personal data up to date.  You should let the HR Adviser dealing with the vacancy you’ve applied for know if personal data you have provided changes during the application process.

If at any stage of the application process you are supplied with personal data relative to others this must not be disclosed inside or outside The OGTC unless you have been authorised to do so.  If you know or suspect that a data breach – leading to the loss or unauthorised access, disclosure or acquisition of personal data – has occurred during the application process please contact the HR Adviser dealing with the vacancy you’ve applied for immediately and follow their instructions. 

If you have any questions, please contact the HR Adviser dealing with the vacancy you’ve applied for.

If you believe that the organisation has not complied with your data protection rights you can complain to the Information Commissioner’s Office (ICO).