Job Applicant Privacy Notice

Cool Earth is a charity that backs people to protect rainforest and fight the climate crisis. Cool Earth is a registered charity in England and Wales (company no. 05938412, charity no. 1117978) and also operates its affiliate in the United States, Cool Earth Action, a non-stock, non-profit company (registration no. 26-3688173).

We are registered as the data controller with the Information Commissioner’s Office (ICO), registration no. ZA270275. Any data we collect will be used in accordance with the requirements of the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).

Cool Earth is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This Job Applicant Privacy Notice sets out what personal data we, Cool Earth, (referred to as ‘the Company’, ‘We’, or ‘Our’) hold about you and how we collect and use it during and after the recruitment process. It applies to anyone who is applying to work for us, whether as an employee, worker, contractor, consultant, intern, volunteer, partner or director (together referred to as ‘Job Applicant’ or ‘you’).

If you have any questions or concerns about how your personal data is being used by us, you can contact by email here or telephone +44 (0)1326 536136.

Note too that you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Details of how to contact the ICO can be found on their website: https://ico.org.uk.

Data controller details

Cool Earth is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: Cool Earth, Tremough Innovation Centre, Penryn TR10 9TA; Telephone 01326 536136.

Data processor details

We use Workable, an online application provided by Workable Software Limited, to assist with Our recruitment process. We use Workable to process personal information as a data processor on Our behalf. Workable is only entitled to process your personal data in accordance with Our instructions.

When you apply for a job opening posted by Us, these Privacy Notice provisions will apply to Our processing of your personal information in addition to Our other Privacy Notice which has been provided to you separately or is available on Our Website.

Data protection principles

In relation to your personal data, we will:

process it fairly, lawfully and in a clear, transparent way
collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
only use it in the way that we have told you about
ensure it is correct and up to date
keep your data for only as long as we need it
process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed

Types of data we process

We may hold many types of data about you, including:

your personal details including your name, address, date of birth, email address, phone numbers;
gender;
marital status;
whether or not you have a disability;
information included on your CV including references, education history and employment history;
documentation relating to your right to work in the UK, Peru, Papua New Guinea, USA;
whether you have been found to have committed Misconduct during previous periods of employment; the nature of the Misconduct; the Disciplinary Measure imposed for the Misconduct; and the date of the Disciplinary Measure by a Participating Organisation, as part of the Misconduct Disclosure Scheme
details of your visits to Workable’s Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Workable’s Website and the resources that you access.

Workable provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

Workable’s technology allows Us to search various databases – some publicly available and others not, which may include your personal data (including your CV or Resumé), to find possible candidates to fill Our job openings. Where We find you in this way We will obtain your personal data from these sources.

We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for Our business more generally.

How we collect your data

We collect data about you in a variety of ways. When you apply for a job at Cool Earth, your data may be processed by Workable, a recruitment management system, on our behalf. We use the application form to collect the information you would normally include in a CV or a job application cover letter, contact details such as your address and telephone number, your employment and education history, and confirmation of your right to work.

During the application process, we also collect data in the form of notes made by our recruiting officers during a recruitment interview.

Further information will be collected directly from you when you complete forms at the start of your employment, for example, your health, bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport, national identity card, or other right to work evidence.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.

All offers of employment are subject to satisfactory references. We will seek information from third parties once a job offer to you has been made and will inform you that we are doing so and seek your explicit consent to do this.

Cool Earth participates in the Inter-Agency Misconduct Disclosure Scheme. In line with this Scheme, we request information from your previous employers about any findings of sexual exploitation, sexual abuse and/or sexual harrassment during employment, or incidents under investigation when you left employment.

Personal data is kept on your application record on the recruitment management system (Workable), in personnel files or within the Company’s HR and IT systems.

Why we process your data

We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:

Process your application and correspond with you about it
Assess whether you have the required skills, experience, qualifications and training for a role within the company
Making informed decisions about who to offer employment to
Making decisions about salary and other benefits
Assessing training needs
Verify information provided by you
Dealing with legal claims made against us
Keep appropriate records of our recruitment process and decisions

When we process your data for reference checks in line with the Misconduct Disclosure Scheme we do this to help make informed recruitment decisions and to prevent individuals who have previously been found to have committed misconduct relating to sexual abuse, sexual exploitation and/or sexual harassment, from being employed in a sector where they are likely to have access to vulnerable individuals and communities and may have opportunities to exploit power imbalances vis a vis such individuals.

Lawful basis for processing

We rely on legitimate interest as the lawful basis on which We collect and use your personal data. Our legitimate interests are the recruitment of staff for Our business.

On a few occasions, we may rely on your consent for the processing of your personal data. In any such case, we will indicate this and ask for your specific informed consent.

Special categories of data

Special categories of data are data relating to your:

Health
Sex life
Sexual orientation
Race
Ethnic origin
Political opinion
Religion
Trade union membership and
Genetic and biometric data.

We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:

You have given explicit consent to the processing
We must process the data in order to carry out our legal obligations
We must process data for reasons of substantial public interest
You have already made the data public.

We will use your special category data:

For the purposes of equal opportunities monitoring
Adjustments for disability/ medical conditions

We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

If you do not provide your data to us

One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not able to process, or continue with (as appropriate), your application.

Sharing your data

Where we store your personal data in our own systems, it is stored in the UK. We have put measures in place to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred process it in a way required by EU and UK data protection laws.

Where we store your personal data in Workable’s systems as Data Controller, it may be stored in the United States, a destination outside the UK, Switzerland or the European Economic Area (“EEA”). Workable Inc. is self-certified under the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the UK and Switzerland that have been transferred to the United States pursuant to the Data Privacy Framework. Workable has certified that it adheres to the Data Privacy Framework Principles with respect to such data.

Your data will be shared with colleagues within the Company on a “need to know” basis where it is necessary for them to undertake their duties with regard to recruitment. This includes, for example, HR and recruitment teams, those in the department where the vacancy is, those who are responsible for screening your application and interviewing you, the IT department where you require access to our systems to undertake any assessments requiring IT equipment and to the administrative teams responsible for contacting you.

Your data will be shared with third parties if you are successful in your job application. In these circumstances, we will share your data in order to obtain references as part of the recruitment process.

We do not share your data with other bodies outside of the European Economic Area during the normal processes of recruitment unless your recruitment relates to working with our in-country teams outside the UK (currently the US, PNG, and Peru). Should there be a need to transfer your data outside of the EEA area, this will be managed as an inter-organisational transfer which means the data will not leave Cool Earth’s systems and Cool Earth’s data protection policies apply throughout.

Protecting your data

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such, including Data Protection policies and training.

Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

How long we keep your data for

If your application is not successful we will keep your data for up to six months once the recruitment exercise ends or from the date we notify you of our decision.

If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.

Your rights in relation to your data

The law on data protection gives you certain rights in relation to the data we hold on you. These are:

The right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice.
The right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request.
The right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it.
The right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
The right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
The right to portability. You may transfer the data that we hold on you for your own purposes.
The right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests.
The right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please write to us at Cool Earth, Tremough Innovation Centre, Penryn TR10 9TA, or contact us here. Note that these rights are not absolute and in some circumstances, we may be entitled to refuse some or all of your request.

Last updated: 25th March 2024