HMRC Talent Network Privacy Notice

 

 

This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).

 

About HMRC's Talent Network

The Talent Network Portal allows individuals to express an interest in working at HMRC through sharing their personal data. When you express an interest, HMRC recruitment teams will make contact with you to discuss your skills, experience and qualifications and potential roles you might be suitable for. Personal data will be stored in the portal and considered for future vacancies that match your interests and experience. 

Where HMRC’s recruitment teams have had contact with individuals outside the Talent Network Portal about working for HMRC, they may migrate their personal data to the Talent Network Portal and consider them for future HMRC vacancies. 

 

Our Privacy Commitment 

HMRC is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information in accordance with data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act (DPA) 2018.  This privacy notice is for the HMRC Clinch Portal.

HMRC is a data controller. This means that we are responsible for deciding how we hold and use personal information about you.

We are required under data protection legislation to notify you of the information contained in this privacy notice.  It is important that you read this notice, together with any other privacy notice that is provided 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 your information.

HMRC is a statutory body with statutory functions and a statutory duty of confidentiality which are set out in legislation in the Commissioners for Revenue and Customs Act 2005. HMRC will only share your information with third parties where we are legally allowed to do so. 

 

Data protection principles

 We’ll comply with data protection law. This says that the personal information we hold about you must be:

1.    Used lawfully, fairly and in a transparent way.

2.    Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3.    Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

4.    Accurate and kept up to date.

5.    Kept in a form that identifies you for only as long as necessary for the purposes we have told you about.

6.    Kept securely.

 

Your data

We will process the following personal data in relation for all the activities above. More details about additional data collected is below:

• Full name
• Contact email
• Contact number
• CV, current or previous employment history, appointments or other outside roles, skills, experience or qualifications.*
• Job interests and role type (including permanent, temporary, contract etc)*
• Website usage**
• IP address, location and device information**

* Whilst you may submit your interest to the Talent Network without submitting your CV or employment history, you may be asked for this at a later date when one of HMRC’s recruiters makes contact with you. This is required to allow recruitment teams to match individual’s interests, qualifications and experience to specific roles. Any information obtained through such conversations may be retained within the Talent Network portal and considered for future vacancies.  

** This information is collated if/when cookies are accepted. 

 

Data security

We have put in place measures to protect the security of your information.

We treat the security of your data very seriously. We have strict security standards, and all our staff and other people who process personal data on our behalf get regular training about how to keep information safe.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. We have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information we collect about you.

We have established procedures to deal with any suspected or actual data security breach and will notify you and the Information Commissioners Office of a suspected or actual breach where we are legally required to do so.

 

Legal basis of processing

The legal basis for processing your personal data is:

• Consent: you as an individual have given clear consent for us to process your personal data for a specific purpose. That purpose is to allow you to express an interest in working for HMRC and for HMRC’s recruitment teams to make contact with you to discuss your skills, experience and qualifications and potential roles you might be suitable for. This may include consideration for future vacancies that match your interests and experience.

 

Purpose

The Purpose for which we are processing your personal data is:

• to allow individuals to express an interest in working at HMRC
• to build a network of talent that can be considered for future HMRC vacancies
• to allow HMRC recruitment teams to make contact with individuals who have expressed an interest in HMRC roles to discuss possible opportunities and complete role matching exercises
• to send emails and text messages to individuals via the portal
• to monitor website usage to better understand individual’s use of the site and the popularity of specific content
• to understand the geographical locations of individuals using the website
• to understand how individuals are accessing the website
• to allow HMRC to build and analyse data reports to better understand the website’s usage and interest in HMRC vacancies
• to resolve any system issues for individuals and/or HMRC colleagues.

 

How we store information and sharing information with third parties

Your personal data will be stored within the Talent Network Portal system, which can be accessed by:

• authorised members of the HMRC Talent Acquisition Team, who may store, use or share personal data on our IT infrastructure and with our data processors who provide email, document management and storage services. This includes but is not limited to Microsoft 365 packages such as Outlook and Teams
• Third party suppliers and sub-processors including:
  o   PageUp People, Clinch and Pathmotion who are the suppliers of the system, support with content creation and technical issue resolution
  o   Mailgun who send emails to individuals via the portal
  o   Twilio who send text messages to individuals

We may also share anonymised, aggregate or summary data internally, with third parties and other public bodies, and we may publish this, but it will not allow any individuals to be identified.

By signing up to this system you are authorising us to share your data with 3rd parties. We’ll share your personal information with third parties where:

• we are required or allowed by law
• it is in the public interest to do so
• you authorise us to do so
• it is necessary for the performance of our functions as a government department or a function of the Crown, another government department or another public authority
• Subject Access or Freedom of Information Requests require us to collate responses

As your personal data is stored on our IT infrastructure, and shared with our data processors who provide email, and document management and storage services, it may be transferred and stored securely outside the European Economic Area. Where that is the case it will be subject to equivalent legal protection through the use of Model Contract Clauses.

We will transfer the personal information we collect about you (or allow our suppliers to do so) to countries outside the UK.

To ensure that your personal information receives an adequate level of protection we never agree to the storing, processing or maintenance of your data outside the UK without undertaking prior assurance activity.

The Supplier Security Steering Group provide an independent control and assess any proposed offshoring of HMRC personal information. That includes assessing whether the host country (and supplier) can provide an adequate level of protection for your personal information in a way that is consistent with and respects UK data protection legislation.

 

Data retention: How long we’ll use your information

We aim to retain your personal information for only as long as it is necessary for us to do so for the purposes for which we are using it and in line with HMRC’s  published records management and retention and disposal policy.

For the purpose of HMRC’s Talent Network, this will be for: 

• 12 months and after this period retention will be reviewed annually. 
• HMRC recruitment teams will contact you annually to update the personal data we hold and to review whether you still wish to remain in HMRC’s Talent Network. If we do not receive a response, we will assume you are no longer interested and will erase the data
• CVs will be renewed or removed after 12 months to ensure accuracy

We shall immediately destroy or dispose of in a secure manner any personal information the retention of which is no longer required.

 

Your rights

You have the right to:

• request access to your personal data 
• request corrections to your personal data if it is inaccurate or incomplete 
• request we delete your personal data
• request to restrict the ways in which we process your data 
• object to HMRC processing your personal data 
• request for a human to review the decision if automated decisions or profiling are made about an individual
• request the transfer of your personal information to another party
• tell us if you are concerned about how your personal data is being used by making a data protection complaint. 

Whilst you always have the right to make a request under one of these rights, in some circumstances we may be unable to do so. Each request will be considered on a case by case basis, and where we cannot meet your request, we will notify you of this. 

Under the legal basis of consent you have the right to withdraw your consent to the processing of your data at any time. 

To withdraw consent for us to process your personal data, or to correct, update, or remove any personal information we hold, please contact the HR Talent Acquisition Team at specialistresourcingteam@hmrc.gov.uk 

 

Complaints

If you consider that your personal data has been misused or mishandled, please notify HMRC of your concerns in the first instance by contacting the Office of the Data Protection Officer (ODPO) using the following contact information: 

External enquiries: advice.dpa@hmrc.gov.uk

Internal enquiries: SM7834189@internal.hmrc.gov.uk

If you have raised your concerns with us via the ODPO and you are not satisfied with the response, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Email: casework@ico.org.uk 

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

 

Contact details

The data controller for your personal data is HMRC. The Data Protection Officer provides independent advice and monitoring of HMRC’s use of personal information.

You can contact HMRC by emailing specialistresourcingteam@hmrc.gov.uk

 

Changes to this privacy notice

We keep our privacy notice under regular review and reserve the right to make changes when necessary. We will inform you by email should we add or change any services listed in this privacy notice which utilise your personal information.

This privacy notice was last updated on 24th July 2023.