Introduction
As a data controller, JLM Mortgage Network Limited (“JLM/we/us/our”) comply with all applicable data protection and privacy legislation in force from time to time in the UK including the General Data Protection Regulation ((EU) 2016/679) and the Data Protection Act 2018. This privacy notice explains what personal data we collect about you (“you/your”) when you apply for a job.
Under the GDPR we are required to notify the Information Commissioner’s Office (ICO) about our use of personal data. Out registered address is JLM Mortgage Network of 21a Churchyard, Hitchin, Hertfordshire, SG5 1HP and you can see our current data notification on the ICO website.
We have policies, procedures, and training in place to help our employees and Regulated Individuals (“employees”) understand their data protection responsibilities and our data protection principles. We have a nominated a senior manager who serves as our Data Protection Manager. If you have any questions regarding how we collect, store and process your personal data, please email compliance@jlmms.co.uk.
We place great importance on ensuring the quality, confidentiality, integrity and availability of the data we hold and in meeting our data protection obligations when processing personal data. JLM is committed to protecting the security of your personal data. We use a variety of technical and organisational measures to help protect your personal data from unauthorised access, use or disclosure.
We update this privacy notice from time to time in response to changes in applicable laws and regulations, to our processing practices or other grant services we offer. When changes are made, we will update the date at the top of this document. Please review this privacy notice periodically to check for updates.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
What personal information we process
When you apply for a role (whether as an employee or a Regulated Individual) or submit your CV (or similar employment information) to us, whether directly or through an agency, or attend an interview, we will collect your personal data. This includes:
We collect special category data in accordance with the Equality Act 2010. We will only do this to make reasonable adjustments in the workplace to enable all candidates to apply for vacancies, attend interviews and to commence employment This is also necessary to ensure we meet our legal obligations when recruiting. We may also collect data for diversity monitoring as an important means of implementing and promoting diversity within the workplace.
Purposes & bases for using your personal data
We may use your data for the following purposes and on the following lawful bases:
Purpose | Lawful Bases for Processing |
Responding to correspondence from you. | It is in our legitimate interest to respond to you when you make an employment or general enquiry. |
Processing your application to assess suitability for employment. | When processing your personal data for the purposes of administering your job application or assessing your candidacy for a role, we do so with your consent. When processing your special category data, we do so with your explicit consent. |
Assessing suitability for employment. | It is our legal obligation under the Equality Act 2010 to protect all applicants from discrimination in the workplace at all stages of pre-employment and employment. When processing your special category data, we do so with your explicit consent. |
Arranging and conducting recruitment interviews, either in person, via telephone or other means. | We rely on your consent to process your personal data to facilitate our recruitment process. |
Obtaining necessary references from third parties and conducting pre-employment screening checks. | We rely on your consent to process your personal data to facilitate our recruitment process. When processing your special category data, we do so with your explicit consent. |
Contacting unsuccessful applicants about future suitable vacancies. | It is our legitimate interest to stay in contact with suitable candidates for future roles. |
Sharing personal data with third parties including government agencies, law enforcement agencies and others. | It is our legal obligation to cooperate fully as and when required by law. When processing your special category data, we do so with your explicit consent. |
Sharing your information
Within JLM, your personal data will only be shared with those who need to have access to it. This will primarily be our HR personnel.
How we protect your data
JLM takes the security of your data seriously. We have 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 its employees in the performance of their duties. Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of the data.
How long we retain personal data
We will retain your personal data for only as long as is necessary for the recruitment process. If your candidacy is successful and you are employed by us, your data will be processed and retained as set out in our employee privacy notice, provided to you with your employment paperwork.
If you are not invited to interview, we will not retain your details, CV or covering letter. If you attend an interview with us but are unsuccessful, we will retain your CV, application details and interview notes for 12 months (from the date of first receipt of your details).
We will also retain personal data where it is necessary to comply with our legal obligations or as necessary in relation to legal claims. This is rare but may mean we need to retain your data for longer than 12 months.
International transfers
We may share your data with service providers and suppliers to our business who process data on our behalf including those in countries outside the UK where the data protection laws are not equivalent to those within the UK. We do so using Standard Contractual Clauses approved by the European Commission and recognized by the UK, on the basis of which data can be transferred outside the UK. The Standard Contractual Clauses oblige the organizations in those countries to comply with the same data protection standards as required in the UK.
Your rights
Individuals whose personal data we hold, and process have the following rights:
If you wish to exercise your rights, please contact us at compliance@jlmms.co.uk or write to us at the address provided below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Employees in the EU also have the right to lodge a complaint with a supervisory authority in a member state of the EU if you believe we are infringing EU data protection laws. In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office if you are concerned about the way in which we are handling your personal data.
Automated decision making
We do not make employment decisions based solely on automated decision making.
Contact us
You can contact JLM in relation to data protection and this privacy notice by writing to:
The Data Protection Manager,
JLM Mortgage Network Ltd,
21a Churchyard,
Hitchin
Hertfordshire
SG5 1HP
Telephone 01462 455 655 or email compliance@jlmms.co.uk
We have also appointed an independent Data Protection Officer at data protection consultants, Evalian Limited who can be contacted by email at dpo@evalian.co.uk.
What if I am still not satisfied?
If you are not satisfied with how JLM has responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.
Changes to this privacy notice
We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.
JLM Mortgage Network Limited Registered Office: 21a Churchyard, Hitchin, Hertfordshire SG5 1HP. Registered company number 4701803. Registered in England and Wales JLM Mortgage Network Limited is authorised and regulated by the Financial Conduct Authority. FCA No. 300629. You can check this on the FCA’s Register by visiting the website https://register.fca.org.uk/ or by contacting the FCA on 0800 111 6768.