Candidate Privacy Policy
HSS ProService Limited (“HSS ProService”, "we" or "us") is committed to protecting the personal data of its job applicants. This Notice sets out important information about how HSS ProService and its associated companies, including HSS Training Limited, collect and use your personal data during the application and recruitment process.
This Notice includes information about our use of the Teamtailor AB applicant tracking system (“ATS”) and the AI-enabled Copilot features used within that system (“Copilot”).
SCOPE
This Notice applies to job applicants located in the UK. In connection with the recruitment process, the relevant data controller is HSS ProService Limited, registered address: Building 2, Think Park, Mosley Road, Manchester, England, M17 1FQ (company number 11084154). Where one of HSS ProService’s associated companies is recruiting for a role, that company may also be a controller for that recruitment process. You should read this Notice carefully and raise any questions you may have with the recruitment team at ProCareers@hss.com.
Teamtailor AB acts as our processor in providing the ATS and Copilot functionality.
WHAT PERSONAL DATA DO WE COLLECT?
Personal data means information which identifies you and relates to you as an individual. We will collect, use and store your personal data for a variety of reasons in connection with the application and recruitment process. We have set out below the main categories of candidate personal data which we process in connection with our recruiting activities:
identity data, including your full name (including previous names), title, date of birth and gender (“Identity Data”)
personal contact information (including your home address, personal telephone number(s) and personal e-mail address) (“Contact Details”)
work history and other relevant experience including information contained in CV (including previous employers, job titles, dates of employment, responsibilities, reasons for leaving, and skills and competencies), cover letter or job application form (including your earliest start date and current employment status) (“Application Data”)
education information including degrees awarded, transcripts and other information provided in support of the job application (“Education and Qualifications”)
professional memberships and qualifications (“Professional Memberships”)
compensation history (including current salary and benefits) (“Compensation Data”)
information collected during phone screenings and interviews (including recruiter assessments, screening notes, interview feedback, suitability commentary, and information regarding previous criminal convictions) (“Interview and Screening Data”)
details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits (“Role Preferences”)
reference information (including reference summaries) and information received from background checks (where applicable)(“References”)
information related to previous applications to us or previous employment history with us (“ProService Employment Data”)
documents evidencing your right to work (including information about your nationality / citizenship and immigration status where relevant) (“Right to Work Information”)
information gathered through our monitoring and/or recording of its IT systems, audio conferencing and telephone systems and building access records (“Recording Data”)
diversity monitoring data, including ethnicity, disability status, age band or other equal opportunities data (“Diversity Monitoring Data”)
recruiter correspondence, including emails or messages relating to you and representations made on your behalf (“Recruiter Correspondence”)
health data, including confirmation of relevant medical conditions, disability status, workplace adjustments or accommodations required for the recruitment process or role, responses to pre-employment health questionnaires, and ability to perform specific job-related tasks (“Health Data”)
recruitment data generated within or by the ATS, including candidate ID, application status, recruitment stage, source of application, hiring manager notes, recruiter notes, screening outcomes, interview scheduling data, audit logs and communications with you (“ATS Data”)
where Copilot is used, artificial intelligence-assisted recruitment data, including AI-generated CV or resume summaries, AI-generated interview transcripts and interview summaries, AI-generated suggested interview questions, AI-generated responses to recruiter questions about candidate information held in the ATS, salary expectation screening results (limited to checking your stated salary expectations against the salary range for the role), candidate suggestion outputs (if you have agreed to future-role consideration), and a meeting insight statistic showing the proportion of interview time during which you spoke (“AI-generated Data”).
Most of the personal data to be provided by you is mandatory in connection with our recruiting activities. Failure to provide mandatory personal data may affect our ability to accomplish the purposes stated in this Notice, including considering your suitability for employment. Other information is optional, including Diversity Monitoring Data, future-role consideration preferences and, where applicable, interview recording. We will tell you where information is optional.
The list set out above is not exhaustive, and there may be other categories of personal data which HSS ProService collects, stores and uses in the context of the application and recruitment process.
Most of the personal data which we process will be collected directly from you. However, we may also collect your personal data from the following sources, including:
recruitment agencies, job boards and recruitment platforms, including LinkedIn and Indeed, from which we collect the following categories of personal data: Identity Data, Contact Details, Application Data, Education and Qualifications, Professional Memberships, Compensation Data, Role Preferences, Right to Work Information, Diversity Monitoring Data, and Recruiter Correspondence
former employers, from which we collect the following categories of personal data: Identity Data, Application Data, Compensation Data, and References
official bodies (such as the Financial Conduct Authority), from which we collect the following categories of personal data: Identity Data and Professional Memberships
medical professionals, from which we collect the following categories of personal data: Identity Data and Health Data
education facilities, from which we collect the following categories of personal data: Identity Data and Education and Qualifications
publicly accessible sources, from which we collect the following categories of personal data: Identity Data, Application Data, Education and Qualifications, and Professional Memberships.
We may generate further recruitment records within the ATS, including the following categories of personal data: ATS Data and AI-generated Data.
REFERENCING AND VETTING
As part of our referencing and vetting procedures, HSS ProService may contact certain third parties to verify your personal information (including personal information that you provide as part of the application and recruitment process). These third parties may include:
former employers to verify your previous employment history
universities and/or other establishments for higher education that you attended to verify your education history
credit referencing agencies (when this is required, we will contact the candidate directly through the recruitment process)
We will only seek this information in relation to successful candidates that have accepted a conditional offer of employment with us, and we will specifically inform such candidates that we will be contacting these third parties in advance of doing so.
HOW AND WHY DO WE USE YOUR PERSONAL DATA?
HSS ProService uses your personal data for a variety of purposes to take steps necessary to enter an employment contract with you (“Contract”), to comply with legal obligations (“Legal Obligations”) or otherwise in pursuit of its legitimate business interests (“Legitimate Interests”). We have set out below the main purposes for which candidate personal data is processed and our lawful basis for that processing:
to identify and evaluate job applicants, including assessing skills, suitability qualifications and experience: Legitimate Interests (to decide whether to appoint you to a role)
verifying candidate information and carrying out prior employment, background and reference checks, where applicable and to prevent fraud: Contract
communicating with you about the recruitment process and your application: Contract
to comply with our legal, regulatory, or other corporate governance requirements: Legal Obligations
to perform analysis of recruitment trends: Legitimate Interests (to improve and support our recruitment process)
We use the ATS to manage applications, communicate with candidates, arrange interviews, record recruitment decisions, manage candidate records, maintain appropriate access controls and retain recruitment information in accordance with our retention policy.
We may use Copilot within the ATS to support recruitment administration and decision-making. Copilot may:
automatically analyse CVs and application materials
automatically create resume summaries
generate interview transcripts and interview summaries where an interview has been recorded
check whether your stated salary expectations are within the salary range offered for the role
suggest interview questions based on the job description and role criteria
help us locate and summarise information already held in the ATS
create a statistic showing the proportion of interview time during which you spoke.
Copilot is used to assist us. It does not replace human judgement. We do not use Copilot for emotion recognition, sentiment analysis, suitability or behavioural scoring, or personality assessment.
Except as explained below, our lawful basis for processing your personal data in the ATS and/or using Copilot is Legitimate Interests (to improve recruitment efficiency, consistency, record keeping and candidate management). These interests are balanced against candidates’ rights and freedoms, and we apply safeguards including transparency, human review, access controls, exclusion of diversity data from Copilot and the right to object.
Where we process your personal data in the ATS directly in connection with entering into an employment contract with you, our lawful basis is Performance of a Contract. This lawful basis will, generally, not apply where we process your personal data using Copilot.
Where we process your personal data in the ATS and/or Copilot directly in connection with a compliance-related check used to support our statutory obligations, our lawful basis is Legal Obligation.
In addition to using your personal data to consider you for the role you applied for, we will retain and process your personal data to inform you about and to consider you for other roles that may be appropriate for you. We do this in pursuit of our legitimate interests in maintaining an efficient recruitment process, reducing the need for candidates to re-submit information, identifying suitable talent for our business more quickly, and ensuring we have access to appropriately qualified candidates for future opportunities. We consider that this processing is proportionate and has minimal privacy impact, as it is limited to recruitment-related purposes, and uses information you have already provided to us. This processing may include using Copilot to help identify candidates in our existing talent pool who may be relevant to open vacancies. Copilot does not make recruitment decisions and any suggestion is reviewed by a recruiter or hiring manager. If you do not want us to consider you for other roles which we consider may be appropriate for you, please inform your Recruitment contact.
We do not rely on consent as the general lawful basis for recruitment processing. Where we ask for your consent for specific optional processing, such as certain diversity monitoring or interview recording, you may decline to give that consent or withdraw that consent at any time. Where recording is optional and you decline recording, Copilot interview transcripts, summaries and meeting insights will not be generated.
This list is not exhaustive and HSS ProService may undertake additional processing of personal data in line with the purposes set out above.
WHAT SPECIAL CATEGORIES OF PERSONAL DATA DO WE PROCESS?
Certain categories of data are considered "special categories of personal data" and are subject to additional safeguards.
HSS ProService will always treat special categories of personal data as confidential and will only share such data internally where there is a specific and legitimate purpose to do so.
HSS ProService limits the special categories of personal data which it processes as follows:
Health Information
HSS ProService may process information about a candidate's physical or mental health in compliance with our obligations owed to disabled applicants, including to consider whether we need to provide appropriate adjustments during the recruitment process.
If a candidate is successful, any health information processed as part of the recruitment process that is relevant to HSS ProServices’ compliance with its obligations in connection with employment will be retained and processed in accordance with the Colleague Privacy Notice.
Equal Opportunities Information
We are committed to providing equal opportunities for employment and monitor information relating to ethnic origin, race, nationality, disability and sexual orientation of applicants alongside information relating to gender and age, for the purposes of equal opportunities monitoring.
We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal data against accidental loss and unauthorized access, use, alteration, or disclosure.
In addition, this monitoring will always take place in accordance with appropriate safeguards as required under applicable law, including:
the provision of information relating to ethnic origin, race, nationality, and disability for the purposes of monitoring will be voluntary and processed for this purpose only with your consent.
wherever possible, the monitoring will be conducted based on using anonymised data so individual employees cannot be identified.
the information processed for monitoring purposes will be maintained separately from general management and HR records.
Health Data and Diversity Monitoring Data is not used to assess your suitability for a role and is not made available to hiring decision-makers in identifiable form. We do not deliberately use Copilot to process, analyse, summarise or infer such information about you.
You should avoid including unnecessary special category information in your CV, application or interview, unless it is relevant to the recruitment process, for example where you are asking us to consider a reasonable adjustment. Where special category information is incidentally included in recruitment materials, we will handle it in accordance with this Notice and our data protection obligations.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
We do not deliberately use Copilot to process, analyse, summarise or infer information about your criminal convictions history.
WHEN DO WE SHARE YOUR PERSONAL DATA?
HSS ProService will share your personal data with other parties only in limited circumstances to take steps necessary to enter into the employment contract where necessary to comply with a legal obligation, or otherwise in pursuit of its legitimate business interests as follows:
recruitment agencies
background vetting specialists
occupational health providers and appointed doctors
accountants, lawyers and other professional advisers
any applicable regulatory body
pension and/or healthcare providers
colleague benefit providers
We may share your personal data with Teamtailor AB, which provides our ATS and Copilot functionality as our processor. Where Copilot is used, Teamtailor AB may transmit relevant data to OpenAI Ireland Ltd (“OpenAI”) through OpenAI’s Enterprise API for AI-based processing. OpenAI acts only as Teamtailor AB’s subprocessor for this purpose and is not permitted to use your personal data for its own purposes. Personal data processed through Copilot is not used to train OpenAI’s models.
Depending on the Copilot feature used, the data transmitted to OpenAI may include Identity Data, Contact Details, Application Data, Education and Qualifications, Professional Memberships, Compensation Data, Interview and Screening Data (except that we will not deliberately transmit information regarding previous criminal convictions), Role Preferences, ProService Employment Data, Recording Data, and Recruiter Correspondence.
Where Meeting Insights or interview transcription is used, Teamtailor AB may use approved transcription providers to create transcripts or related meeting outputs.
Other than where HSS ProService shares personal data with a regulatory or governmental body, your personal data will only be shared under the terms of a written agreement between HSS ProService and the third party which includes appropriate security measures to protect the personal data in line with this notice and our obligations. The third parties are permitted to use the personal data only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission.
FOR HOW LONG WILL MY PERSONAL DATA BE RETAINED?
HSS ProService policy is to retain personal data only for as long as needed to fulfil the purposes for which it was collected, or otherwise as required under applicable laws and regulations. Under some circumstances we may anonymise your personal data so that it can no longer be associated with you. We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice to you.
For unsuccessful candidates:
We will typically retain personal data collected during the recruitment process for a maximum period of 12 months from the end of the process subject to any exceptional circumstances.
We will typically retain personal data held in archived e-mails or other electronic files for approximately 6 months.
We retain your personal information for the periods set out above so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After such periods, we will securely destroy your personal information in accordance with applicable laws and regulations.
If you are offered and accept employment with us, the personal data we collected during the application and recruitment process will become part of your employment record and we will use it in connection with your employment in accordance with the Colleague Privacy Notice.
INTERNATIONAL TRANSFERS
We use the European processing region for the ATS and Copilot functionality. Some service providers or subprocessors may process or access personal data from outside the UK, the European Economic Area or Switzerland. Where this happens, we will ensure that appropriate safeguards are in place, such as adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.
WHAT ARE MY RIGHTS IN RELATION TO MY PERSONAL DATA?
HSS ProService will always seek to process your personal data in accordance with its obligations and your rights.
We do not make recruitment decisions solely by automated means. Copilot may assist us by summarising information, generating transcripts, checking salary expectations and suggesting candidates or interview questions, but human recruiters and hiring managers remain responsible for recruitment decisions.
Decisions to shortlist, reject, interview or appoint a candidate are made by authorised people after considering relevant information. Copilot outputs are advisory only and are not treated as determinative. In certain circumstances, you have the right to seek the erasure or correction of your personal data, to object to aspects of how your data is processed, and otherwise to seek the restriction of the processing of your personal data. You also have the right to request the transfer of your personal data to another party in a commonly used format.
Where we rely on Legitimate Interest, including for Copilot-assisted processing, you have the right to object to that processing. If you object, we will consider your objection and stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or the processing is needed for legal claims.
You may also ask us to review or explain a recruitment outcome where you are concerned that Copilot output may have affected the process.
If you have any questions about these rights, please contact the recruitment team at ProCareers@hss.com.
You have a separate right of access to your personal data processed by HSS ProService. You may be asked for information to confirm your identity and/or to assist HSS ProService to locate the data you are seeking as part of HSS ProServices’ response to your request.
If you wish to exercise your right of access, or if you have any questions or concerns about this privacy policy or how we handle your personal information, you should set out your request in writing to: HSS ProService, HR Dept., Building 2, Think Park, Mosley Road, Manchester, England, M17 1FQ.
Finally, you have the right to raise any concerns about how your personal data is being processed with the Information Commissioner's Office (ICO) by going to the ICO's website: https://ico.org.uk/concerns/ or contacting the ICO on 0303 123 1113 or casework@ico.org.
