Privacy Policy


Introduction 

Whether you already work with us or are hoping to join us, we want our recruitment processes to be clear, fair and respectful. This policy explains what personal information we use during recruitment, why we use it and the choices available to you. 
Cooplands & Son (Scarborough) Limited is responsible for deciding how and why your personal information is used during recruitment. In data protection law, this means we are the controller. 

What you need to know 


 

  • This policy applies to external and internal candidates. It covers you if you apply for or express interest in a role, are introduced by a recruitment agency, are approached about an opportunity, join our talent pool, or are considered for another role 
 

  • If you already work for us, this policy should be read alongside our Privacy Notice. That notice continues to apply to information we hold about you as a colleague 
 

  • Pinpoint provides our recruitment system and processes candidate information on our behalf and under our instructions 
 

  • This policy does not cover Pinpoint’s separate use of information where it acts for its own purposes, such as information collected when you use its own website 

The information we use 

We may collect and use: 
  • your name, contact details and preferred way to contact you 
  • your application, CV, employment history, qualifications, skills and experience 
  • if you are an internal candidate, relevant information already held in your colleague record, such as your current role, work history with us, training, qualifications and contact details 
  • your answers to application or screening questions, interview notes, assessments, scores and feedback 
  • communications with you and records of the recruitment process 
  • information about your right to work, identity and any pre-employment checks required for the role 
  • references and information provided by referees, recruitment agencies or other relevant sources 
  • information about reasonable adjustments, health or disability where you choose to tell us or where it is needed for the recruitment process 
  • equal opportunities monitoring information, where collected. We keep this separate from selection decisions wherever practicable 
  • Where relevant to the role, and normally after a conditional offer has been made, we may collect limited health or medical information through a pre-employment health questionnaire or occupational health assessment. This may include information needed to assess fitness for the role, identify reasonable adjustments, or meet health and safety and food safety requirements 
  • Before a conditional offer, we will only ask health or disability-related questions where legally permitted, such as to arrange reasonable adjustments during recruitment or establish whether a candidate can perform an intrinsic function of the role. Role-dependent health or medical questions will normally be asked only after a conditional offer has been made 
Please only provide information that is relevant to your application. Do not include sensitive information about another person unless it is necessary and you are authorised to do so. 
How we collect your information 
We may collect the following information: 
  • directly from you, including through Pinpoint, email, telephone, interview or any required assessments 
  • from people involved in the recruitment process, including hiring managers and the HR team 
  • if you are an internal candidate, from relevant business systems and your existing colleague record where the information is necessary for your application 
  • from referees, recruitment agencies, background-check providers and right-to-work services, where relevant 
  • from information you have made publicly available for professional purposes, such as a professional networking profile, where it is reasonable and relevant 
  • from Pinpoint and connected recruitment services used to administer your application 

Why we use your information 


Managing your application 

We use your information to receive, review and progress your application; arrange interviews or assessments; communicate with you; record decisions; and make an offer where appropriate. For some roles, we use limited health or medical information to assess fitness for work, identify reasonable adjustments and meet our employment, health and safety and food safety responsibilities. 

Checking suitability 

We use your information to assess your skills, experience and suitability, verify information, obtain references and complete proportionate pre-employment checks where required. 

Meeting our legal responsibilities 

We use information where needed to check your right to work, make reasonable adjustments, support equal opportunities, prevent unlawful discrimination and establish, exercise or defend legal claims. 

Maintaining records 

We use recruitment information to understand recruitment activity, monitor fairness and effectiveness, improve candidate experience, produce aggregated reporting, demonstrate that we followed a fair process, respond to questions or complaints and protect the rights and interests of any candidates and colleagues. 

Our lawful bases 

Depending on why we are using your personal information, we rely on one or more of the following lawful bases: 
  • taking steps at your request before entering into an employment contract; 
  • complying with our legal obligations, including our right-to-work, equality, employment, health and safety and, where relevant, food safety responsibilities; 
  • our legitimate interests in recruiting suitable people, operating an effective and fair recruitment process, protecting our business and keeping appropriate recruitment records; and 
  • your consent where we specifically ask for it—for example, to retain your details in our talent pool for future opportunities. You may withdraw your consent at any time. 
Health and medical information, information about disabilities and certain equal opportunities monitoring information may be classed as special category personal data. Where we use this information, we must have both a lawful basis and an additional condition under data protection law. 
Depending on the purpose, we will usually process special category information because it is necessary to: 
  • meet our obligations and exercise our rights under employment and social protection law, including identifying and providing reasonable adjustments 
  • assess your working capacity, where this is undertaken by or under the responsibility of an appropriate health professional 
  • monitor equality of opportunity where permitted under data protection law 
  • establish, exercise or defend legal claims 
  •  
We only collect and use special category information that is necessary and proportionate for the relevant purpose. We do not rely on consent for mandatory, role-dependent health checks. 
We only use information about criminal convictions or offences where it is necessary, proportionate and legally permitted. 

Who we share your information with 

We may share relevant information with: 
  • the HR team, relevant hiring managers, interviewers and authorised colleagues who need it for the recruitment process 
  • if you are an internal candidate, your current manager or another relevant manager where this is necessary to verify information or manage a potential move. We will normally discuss this with you before doing so unless there is a clear reason not to 
  • Pinpoint, which provides our applicant tracking system and acts on our instructions 
  • service providers supporting recruitment, such as recruitment agencies, assessment providers, reference or background-check providers, right-to-work services, IT support and professional advisers 
  • public bodies, regulators, law-enforcement agencies or courts where we are required or permitted by law 
  • another organisation where this is necessary as part of a business sale, restructure or transfer, subject to appropriate safeguards 
  • We may share relevant information with an occupational health provider or other medical professional where an assessment is necessary. Access within Cooplands is restricted to those who need the information. Wherever possible, recruiting managers receive only confirmation of fitness for work, relevant restrictions or recommended adjustments—not detailed medical information or a diagnosis 
We do not sell candidate information. Access is limited according to role and business need. Service providers must protect the information and may only use it for the agreed purpose. 

International transfers 

Some suppliers or their support services may process information outside the UK. Where this happens, we use an approved transfer mechanism and appropriate safeguards, as required by data protection law. You can contact us for more information about the safeguards that apply. 

How long we keep your information 

If you are unsuccessful, we normally keep your recruitment record for six months after the recruitment process ends. 
If you are an external candidate and agree to join our talent pool, we keep your profile for up to 12 months from your consent, unless you withdraw sooner or we ask you to renew it. 
For internal candidates, information already held in your colleague record continues to be retained under our Colleague Privacy Notice and retention schedule. 
If you are successful, information needed to start and manage your employment or appointment will become part of your colleague record. Information that is no longer needed will be deleted or anonymised. 
Health or medical information collected during recruitment is retained only for as long as it is necessary for the purpose for which it was collected. If you are successful, information that remains relevant to your employment will become part of your colleague record and will be retained in accordance with our Colleague Privacy Notice and retention schedule. Detailed medical information will not be retained where a fitness-for-work outcome or record of agreed adjustments is sufficient. 

Automated decisions and profiling 

Pinpoint may help us organise applications, apply job-related screening criteria, search candidate profiles or produce recruitment information. We do not make a decision with a legal or similarly significant effect on you solely by automated means. A person makes or reviews recruitment decisions. If this changes, we will tell you about the logic involved, the likely effect and the safeguards available to you. 

If you do not provide information 

You do not have to provide information that is optional. However, if we need information to assess your application, meet a legal requirement or complete a necessary check, we may not be able to progress your application without it. We will explain this where relevant. 

Your rights 

Depending on the circumstances, you may have the right to: 
  • ask for access to your personal information 
  • ask us to correct information that is inaccurate or incomplete 
  • ask us to delete information or restrict how we use it 
  • object where we rely on legitimate interests 
  • receive certain information in a portable format 
  • withdraw consent at any time, without affecting earlier lawful use 
  • ask for human intervention if a significant decision is ever made solely by automated means 
These rights are not absolute. We will explain if a legal condition or exemption applies. You can also use Pinpoint’s candidate data-management options where these are available. 

Contact us or raise a concern 

If you have a question, want to exercise a right or are concerned about how we use your information, contact the Recruitment team at recruitment@cooplands-bakery.co.uk. We may need to confirm your identity before acting on a request. 
You also have the right to complain to the Information Commissioner’s Office (ICO). We would welcome the opportunity to address your concern first. Visit ico.org.uk or call 0303 123 1113. 
The Candidate Privacy Policy will be made available to all candidates. We reserve the right to review and amend this policy from time to time.