We use your information in several different ways, for different reasons — what we do with it, depends on the type of information that you provide to us and the reason why we need to ask for it. You don’t have to give us any of your personal information, but if we are collecting your data to consider your application and as a step prior to entering into an employment contract with you, and it’s necessary to enter into that contract, we will be unable to process your application or provide you with employment if you choose not to provide your information.

• If you visit a third-party website i.e. recruitment company and make an enquiry or apply for a job at Essential Insurance and you submit your CV and/or cover letter to provide details such as your name, contact details, date of birth, employment and education history, the third-party will introduce you by passing on your details to us. We’ll use the details provided to process your enquiry and start to evaluate your suitability for the roles available. It’s the same if you call us directly, fill in a form or submit your CV/and or cover letter through our website, we are using these details at your request, to contact you as a first step prior to the possibility of entering into an employment contract with us.

  Whilst we don’t ask for sensitive or special category information early on in the application process, if you choose to provide details such as your ethnic origin, race, religion or political beliefs, we will process the data as is necessary for the purposes of carrying out our obligations in connection with your potential employment and we’ll ensure the necessary safeguards to protect this more sensitive personal information.

• To keep you informed as your application progresses and perform our employer contractual duties, we’ll use your contact details to send you (by letter, email, telephone or any other appropriate means) any information that’s required in relation to the job you have enquired about and the employment contract that you may, or may not, be offered.
• If your CV is shortlisted, to determine your suitability for a role, we may telephone you, or interview you in person, to ask more questions about you. We are obligated to do this to ensure that anyone we employ meets the high standards that are expected of us as a broker that provides an advised service and one who is authorised and regulated by the Financial Conduct Authority (FCA). Prior to offering you an employment contract, we must ask you questions to take into consideration your competence before we can make an offer of employment to you.
• During face to face interviews, potential employees will be asked to complete an application form, which will be utilised during the interview process and kept for our records. To check your background, some of the questions relate to criminal convictions. Many of the employment positions at Essential Insurance require a high degree of trust and integrity and we process information about your criminal convictions if you are applying for certain roles at Essential Insurance. We do this to control risks of regulatory concern; to protect consumers against dishonesty and safeguard the integrity of the UK financial system by managing risks relating to financial crime. In addition, we are legally required and authorised to carry out further background checks such as standard criminal record checks through the Disclosure and Barring Service (DBS) to satisfy ourselves that there is nothing that makes you unsuitable for certain roles.
• If you are offered a contract of employment this will be subject to supply of additional personal information. We will use your personal information to verify your identity, check references and ensure that you are legally entitled to work in the UK or in other instances where we have a legal or regulatory obligation to do so, for example, to adhere to anti-money laundering regulations.
• Upon commencement of a contract of employment, we will pass some of the information you have provided securely to our human resources storage platform. It is in our legitimate interest to have a secure, confidential platform to store personal information that we are required to keep record of in accordance with our legal and contractual obligations as an employer. We will set you up a secure account which we’ll both be able to access and use to record personal information and manage matters such as holidays, sickness and store other personnel documents. For example, we will also store the basic information we need to ensure you get paid and taxed correctly, this includes your national insurance and bank details which we keep on record and pass securely to relevant third parties in connection with processing payroll.
• You will also be asked to provide details of your next of kin and/or emergency contact details, which we will collect and securely store on our human resources platform and will only use in your best interests in order that a loved one or family member can be contacted if you take seriously ill at work for example.
• As a new starter and throughout your employment, we will collect, use and store information about your medical history, current physical and mental health and wellbeing, medication and/or disability status as is necessary to ensure your health and safety in the workplace. As well as being the law, we believe it is part and parcel of being a good employer to make sure you aren't at risk because of the work you do for us. We use this type of information to assess your fitness to work, to provide appropriate workplace adjustments, to ensure we provide support to enable you to perform to your best ability, to monitor and manage sickness absence and administer benefits appropriately and in accordance with our contractual, health and safety or legal obligations. Any information you provide will be treated confidentially and we'll ensure the necessary safeguards to protect this more sensitive information.
• During the course of your employment contract, as an FCA authorised and regulated company, we are legally obliged to ensure all our employees are competent for their role and represent the company values. It is in our legitimate interests to make sure the best service is being provided to our customers and throughout the course of your employment you will be subject to ongoing assessments to ensure you attain and maintain performance to company standards. This involves us keeping records of performance reviews and assessments to allow us to provide you with necessary training and development and put mechanisms in place so that we can support all staff in maintaining competence.
• Our telephone and IT systems are used to keep records and to audit the work that we do, therefore all calls and emails to and from our business are recorded and monitored. We are lawfully doing this because of the nature of our business. Our company policy is that business telephones and email are not to be used for personal matters. This is to avoid your personal information (that we do not require) being processed inadvertently and to prevent it from being kept for reasons you have not been informed about.
• If you choose to terminate your contract of employment with us and take up employment with another company, we will share information about you with future employers if we have a legal or statutory obligation to do so.
• If a customer, insurance provider, a regulator or another authority makes a complaint about us, or any of our employees, about the service that has been provided or advice given, we may use your personal information to investigate the complaint. We are contractually obligated to both you and our customers to deal with complaints appropriately.
• Your personal information may also further be used for statistical analysis purposes. For example, we will report internally on training, competency and performance. We do this to help develop our business, assess our performance and plan for the future.

We do not, and will not, sell any of your personal data to any third party. We believe that this is essential to maintaining our relationship with you. However, we do pass your personal information securely to the following categories of companies, as an essential part of being able to provide our services as an employer:

• HR consultants and software provider – to help us provide correct advice on HR matters and provide a secure platform to manage and handle your personal information confidentially and securely.
• Quality assurance auditors – companies who provide professional services to make sure we are complying with the rules of our regulator, the FCA and independently provide assessment of our competence.
• Communication providers – companies who manage our phone systems and the distribution of post, email and text messages who need access to your personal information and so you can communicate with customers as an employee and so we can communicate with you.
• Related and associated companies – if your job enquiry comes to us via a third-party ‘introducer’ such as a recruitment company or a related company, there will be an exchange of reports to whether you do, or do not take up employment for administrative, management forecasting and planning and statistical purposes. And other related or associated companies such as insurance providers or quote providers will need to handle your personal information to allow you to do your work and fulfil your role.
• Regulators and authorities – upon their request and as we may be required to do so either by law or during investigation of a complaint.
• Law enforcement and fraud prevention agencies – we will share your data when we are required to do so under a legal or regulatory obligation or court order, so we can help tackle fraud.
• Payroll, pension, HMRC and tax specialists – if you work for us, we will share relevant personal information with these specialists or organisations and so they can make sure you receive the correct benefits and remuneration.

If the company receiving your personal information is processing the data to provide elements of our service to you as your employer, such as quality assurance auditors or payroll, pension or tax specialists, we have a contract in place with them to ensure that they cannot do anything with your personal information, unless we instruct them to. They will not share your personal information with any other organisation without our authorisation, they will hold it securely and they must comply with their data protection obligations.

We do not routinely transfer your personal information outside the UK or European Economic Area (EEA) where transfer of data is not restricted, and additional safeguards are not required to protect your data. However, a product or service may be administered from a country outside Europe. Any personal data received from companies transferring from the EEA must comply with EU data protection laws, and we will only transfer personal data outside of the EEA if the organisation receiving your personal data has provided adequate safeguards, we have an international data transfer agreement in place and your rights under UK General Data Protection Regulation are enforceable.

If you are employed by us, we’ll hold on to your information for as long as is needed be able to provide our services as an employer to you, and for as least as long as we have a contract of employment with you.Your personal information will also be held as long as is necessary or required to comply with legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or to handle complaints. For these reasons we’ll keep your information for accurate records and evidence that may be required to help resolve the problem, provide risk related reporting and quality of service analysis.

We may even keep your information for a reasonable period of time even if you are unsuccessful with your application or after your employment contract and relationship with us has ended. However, we do periodically review data that we hold to decide whether it is still necessary to keep hold of some of your information if your employment contract is no longer in place, you have resigned, or your contract has been terminated, or your information is no longer needed because we didn’t agree a contract with you.

In the absence of specific legal, regulatory or contractual requirements but it’s necessary to keep your information for administrative, management forecasting and planning and statistical purposes, we will limit what we keep where possible to minimise risk and safeguard personal information.

You have a lot of rights relating to your personal information:

• The right to be informed about how we use your personal information (that’s why we have produced this notice)
• The right to ask for confirmation of and access to the personal information we hold about you
• The right to ask us to amend your information if it is inaccurate or incomplete
• The right to request that we delete your information, or stop using it in some circumstances
• The right to complain to the data protection regulator in the UK, the Information Commissioner’s Office