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Why does the GLA process personal data?

Under the UK General Data Protection Regulation (UK GDPR), the GLA is only allowed to use personal information if we have a valid reason or ‘lawful basis’ to do so. In the case of your employment with the GLA, there are a number of these ‘lawful bases’ we rely on, which are:

For the ‘performance of a contract’, for example:

  • to take steps at your request to assess your suitability to enter into a contract with you and following an offer of employment, to comply with obligations contained in your contract of employment and the GLA’s HR policies.

Legal obligations (where we are obliged to handle your information in a certain way), for example:

  • to check your entitlement to work in the UK, to prepare to deduct tax and to comply with health and safety laws.

Where you have given your consent to the GLA, for example:

  • you have shared disability information with us and asked to be considered under the GLA’s Guaranteed Interview Scheme.

Sometimes we also need to collect or store information that is called ‘special category personal data’ which is defined as the following:

  • race and ethnic origin
  • politics and religion
  • trade union membership
  • health (physical or mental)
  • sex life or sexual orientation.

The UK Data Protection Act 2018 includes information about criminal allegations, proceedings or convictions on the list of special categories compiled under the UK GDPR. As before, there are a number of ‘lawful bases’ we rely on when handling this kind of information, depending on the circumstances, which are:

  • where we have your explicit consent to do so for a specific purpose
  • where it's necessary for carrying out the obligations and exercising specific rights of the GLA or you in the field of employment and social security and social protection law
  • for the establishment, exercise or defence of legal claims
  • where it is necessary for occupational health purposes (including counselling)
  • where it is necessary for the purpose of administering your occupational pension
  • where it's necessary for equality of opportunity or treatment
  • where it's necessary for the prevention and detection of crime or fraud
  • where processing is necessary for the purpose of a function conferred on the GLA by an enactment or rule of law.

The GLA processes information about trade union membership to administer TU subscriptions from payroll.

The GLA processes special category of personal data, including ethnic origin, sexual orientation, religion or belief, whether you have a disability or not, for purposes of equality monitoring. 

This includes the processing of special category data in line with the Public Sector Equality Duty under the Equality Act (2010) to monitor the demographic data, in particular gender, ethnicity and disability at each stage of the recruitment process, to promote equality throughout the application, selection and interview stages. The GLA will also use the monitoring of demographic data to inform decision making on how a recruitment campaign will proceed. 

Our equal opportunities monitoring form is designed to allow you to select ‘prefer not to say’ for categories that you do not wish to provide information. There is no detrimental effect on your application if you choose this option for the special categories of data.    

For all of our roles, the GLA asks applicants to declare unspent criminal convictions, cautions or bind-overs. The information is considered by the HR team at the point an offer of employment is made; at which point the GLA would consider if the declaration made is one which would make the applicant unsuitable for the type of work to be completed.

For some of our roles, the GLA is obliged to complete a security vetting check and you will be asked to submit information as part of any application for security clearance. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment. We will make it clear to you through the application process those roles where security clearance is required.

The GLA may use aggregated or depersonalised employee data for analysis purposes - for example to ensure that we have an efficient and diverse workforce - or for occupational health purposes. Individuals will not be identified using this information.

Our equal opportunities monitoring form is designed to allow you to select ‘prefer not to say’ for categories that you do not wish to provide information. There is no detrimental effect on your application if you choose this option for the special categories of data.    

Who has access to your data?

Your personal information will only be accessed and processed by authorised personnel (such as line managers, recruitment panels, HR professionals and occupational health professionals) who are involved in the management and administration of the recruitment process and have a legitimate need to access your information for certain specific purposes, such as:

  • Recruitment and HR teams - for example administering the recruitment process
  • line managers and recruitment panels - for example assessing your suitability for a GLA job.

Your sensitive data provided as part of the equalities monitoring form or for the purpose of the guaranteed interview scheme are only viewed by the Resourcing team and wider HR unit as is necessary to perform their duties.

Equal opportunities data collected during recruitment will be used both for monitoring purposes and to inform decision making. Hiring managers will be provided with anonymised equal opportunities data for the applicant pool and shortlist pool. The hiring manager may use that data to inform whether a recruitment campaign proceeds, or some other action. It is therefore possible that protected characteristics of some applicants may be apparent where a hiring manager extends a shortlist in order to seek a more diverse shortlist pool.

Your declaration of unspent criminal convictions cautions or bind-overs is only available to the HR team and will not be considered until you are offered a role with the GLA.

The GLA will share your personal data with and request information about your personal data from previous employers to complete the reference checking process.

Third parties who process data on the GLA’s behalf

The GLA has agreements with third party service providers who provide specialist services on our behalf:

  • Transport for London's Occupational Health Team - provide the GLA’s OH contract
  • Transport for London - provide employment law advice to the GLA
  • Transport for London – who provide a shared service for the GLA including the running of recruitment campaigns and employee record keeping on its HR database/system
  • the Disclosure and Barring Service to obtain necessary criminal records checks
  • employment background check providers to obtain necessary background checks
  • The GLA has a contract with Havas People Limited to support a number of recruitment campaigns for the GLA. Havas People may conduct employment reference checks for successful candidates during the recruitment process.

These third parties will process personal information in accordance with the GLA’s instructions and make decisions regarding the information as part of the delivery of their services; they are also required to put in place appropriate security measures that ensure an adequate level of protection for personal information.

The GLA will not transfer your data outside the European Economic Area.

Automated processing and profiling

To comply with the data protection legislation, the GLA and OPDC must let you know that your personal information is processed 'automatically' using our computers or other systems, or we use it to make an automated decision (without human intervention) that may significantly affect you.

GLA and OPDC may use a third-party anonymising tool to automate the removal of personal data from CVs and covering letters to prevent unfair or unlawful discrimination. If you wish to discuss this or raise a concern about the automatic removal of personal information from CVs and covering letters, please bring this to the attention of the Recruitment Consultant.

GLA and OPDC do not make any recruitment related decisions based solely on the use of automated systems, databases, or computer applications.


How does the GLA protect data?

The GLA takes the security of your data seriously. We have internal policies and technical measures in place to safeguard your personal information.

Access to systems that hold employment-related information is restricted to authorised personnel through the use of unique identifiers and passwords. Your information is stored on systems that are protected by secure network architectures and are backed-up on a regular basis for disaster recovery and business continuity purposes and to avoid the risk of inadvertent erasure or destruction.

How long does the GLA keep data?

If you were not successful in obtaining a role with the GLA, your personal data will remain on file for 12 months from the data you submitted your application.

If you are successful in obtaining a role with the GLA, your personal data will remain on file for the duration of your employment and for six years after the end of your employment. 

The GLA holds your personal data after a recruitment process or after you have left employment to enable us to:

  • respond to correspondence, concerns or complaints
  • maintain records according to rules that apply to us (for example employment law or financial regulations)
  • establish and defend any legal rights.

Your rights

Under the UK General Data Protection Regulation (GDPR), you are entitled to ask to see any personal information that we hold about you. You also have a number of other information rights which include:

  • the right to question any information we have about you that you think is wrong or incomplete
  • the right to object to how we use your information or to ask us to delete or restrict how we use it
  • in some cases, the right to receive a copy of your information in a format that you can easily re-use for your own purpose(s)
  • the right to complain to our Data Protection Officer.

If you would like to exercise any of these rights, please contact the GLA’s Data Protection Officer: [email protected]

if you believe that the organisation has not complied with your data protection rights, you can also complain to the Information Commissioner's Office (ICO), the UK's independent body set up to uphold information rights.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process.

You are under no obligation to provide any information for equal opportunities monitoring purposes and there is no detriment for your application if you choose not to provide such information.

We do however, review the demographic data of the applicant pool and shortlist to promote equality throughout the application, selection and interview stages.

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