This privacy notice applies to applicants and those registering their interest for the Police Now Frontline Leadership Programme
A summary of what this notice explains
Police Now is committed to protecting the privacy and security of personal data.
This notice explains what personal data Police Now holds about you, how we use it internally, how we share it, how long we keep it and what your legal rights are in relation to it.
For the parts of your personal data that you supply to us, this notice also explains the basis on which you are required or requested to provide the information. For the parts of your personal data that we generate about you, or that we receive from others, it explains the source of the data.
There may be instances where we process your personal data on the basis of your consent. Where your consent is needed, you will be specifically asked for consent at the time we collect or need to process the data.
Police Now has published separate notices, which are applicable to other groups, such as successful applicants. Those notices may also apply to you, depending on your circumstances, and it is important that you read this privacy notice together with any other applicable privacy notices, to obtain a complete picture of how your data will be managed by Police Now.
What is your personal data and how does the law regulate our use of it?
“Personal data” is information relating to you as a living, identifiable individual. We refer to this as “your data”.
“Processing” your data includes various operations that may be carried out on your data, including collecting, recording, organising, using, disclosing, storing and deleting it.
Data protection law requires us:
- To process your data in a lawful, fair and transparent way;
- To only collect your data for explicit and legitimate purposes;
- To only collect data that is relevant, and limited to the purpose(s) we have told you about;
- To ensure that your data is accurate and up to date;
- To ensure that your data is only kept as long as necessary for the purpose(s) we have told you about;
- To ensure that appropriate security measures are used to protect your data.
Police Now’s Contact Details
If you need to contact us about your data, please contact [email protected].
Data that you provide to us and the possible consequences of you not providing it
In order for us to process your registration of interest and/or application, it is a necessary requirement that you provide us with your personal data. If you do not provide us with required information, the consequences will depend on the particular circumstances. In many cases we will not be able to process your registration of interest and/or application.
Other sources of your data
Apart from the data that you provide to us, we may generate data about you.
The lawful basis on which we process your data
The law requires that we provide you with information about the lawful basis on which we process your personal data, and for what purposes.
We will primarily process your personal data on the basis of Police Now and/or someone else’s legitimate interests, except where those interests are overridden by your data protection rights and freedoms.
To the extent we enter into any contract with you, we will also process your data on the basis of that contract with you.
Police Now has a number of legitimate interests when receiving, considering and administering registrations of interest and/or applications from prospective participants, including:
- ensuring your suitability for the roles you are seeking to apply for,
- communicating with you and partner police forces, and
- administering an efficient and appropriate programme.
How we apply further protection in the case of “Special Categories” of personal data
"Special categories" of particularly sensitive personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data.
The Special Categories of personal data consist of data revealing:
- racial or ethnic origin;
- political opinions;
- religious or philosophical beliefs;
- trade union membership.
They also consist of the processing of:
- genetic data;
- biometric data for the purpose of uniquely identifying someone;
- data concerning health and certain other sensitive information that should ordinarily be subject to additional protections.
We may process special categories of personal data in the following circumstances:
- Where there is a legal obligation;
- Where it is necessary in the substantial public interest, and further conditions are met; or
- With your explicit written consent;
We have in place safeguards which we are required by law to maintain when processing such data. Less commonly, we may process this type of data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the data public.
Criminal convictions and allegations of criminal activity
Further legal controls apply to data relating to criminal convictions and allegations of criminal activity. We may process such data on the same grounds as those identified for “special categories” above.
Details of our processing activities, including our lawful basis for processing
We have considered carefully the processing activities that we undertake, the source of the data we receive, the reasons why we process it, how long we keep it and the lawful basis we rely on.
Data that we process regarding applicants includes (but is not limited to):
- The contact details that you provide to us, including names, email addresses, addresses and telephone numbers.
- Copies of passports, proof of address, and immigration and citizenship data, to confirm your identity and rights.
- Your application paperwork, including the results of any testing and records of any decisions made in relation to your application.
- Details of your qualifications and correspondence in relation to them.
- Details of your employment and financial history;
- Requests for special arrangements and/or waiver of eligibility criteria, including our consideration and decisions in relation to the same.
- Details of any medical issues and/or disabilities that you have notified to us, including any consideration and decision on reasonable adjustments made as a result; and
- Equality monitoring data.
How we share your data
We will not sell your data to third parties. We will only share it with third parties if we are allowed or required to do so by law.
We may disclose your information to third parties where we consider it necessary for Police Now to operate effectively, provided we are satisfied that appropriate safeguards have been put in place to ensure adequate levels of security for your data. Examples of bodies to whom we may voluntarily disclose data include but are not limited to:
- Police forces with whom Police Now partners in order to place scheme participants..
- We may need to share your data with other professional advisers, auditors, and contractual counter parties in order to fulfil our legal obligations or for the efficient functioning of our organisation.
- You may also ask us to share your data with others.
All our third party service providers are required to take appropriate security measures to protect your personal information in line with our policies, and are only permitted to process your personal data for specific purposes in accordance with UK data protection legislation.
Sharing your data outside the European Union
The law provides various further safeguards where data is transferred outside of the UK/EU.
We may transfer your data outside the United Kingdom/European Union, but only for the purposes referred to in this notice and provided either:
- There is a decision of the UK Government/European Commission that the level of protection of personal data in the recipient country is adequate; or
- Appropriate safeguards are in place to ensure that your data is treated in accordance with UK data protection law, for example through the use of standard contractual clauses; or
- There is an applicable derogation in law which permits the transfer in the absence of an adequacy decision or an appropriate safeguard.
How long we keep your data
The period for which we retain your data will depend on the specific type of data. Data concerning successful applicants will be retained in the application system for up to 5 years, or longer if required by law. Successful applicants’ data will also be transferred to other systems as needed during the course of the programme, and alumni data may also be retained. Please consult the relevant privacy notices for further information.
Unsuccessful applicants’ data will be anonymised 24 months after the end of the relevant recruitment cycle, unless we are required to retain the data by law or have a legitimate interest in retaining the data for a longer period.
Your legal rights over your data
Subject to certain conditions set out in UK data protection law, you have:
- The right to request access to a copy of your data, as well as to be informed of various information about how your data is being used;
- The right to have any inaccuracies in your data corrected, which may include the right to have any incomplete data completed;
- The right to have your personal data erased in certain circumstances;
- The right to have the processing of your data suspended, for example if you want us to establish the accuracy of the data we are processing;
- The right to receive a copy of data you have provided to us, and have that transmitted to another data controller.
- The right to object to any direct marketing (for example, email marketing or phone calls) by us, and to require us to stop such marketing.
- The right to object to the processing of your information if we are relying on a “legitimate interest” for the processing or where the processing is necessary for the performance of a task carried out in the public interest.
- The right to object to any automated decision-making about you which produces legal effects or otherwise significantly affects you.
- Where the lawful basis for processing your data is consent, you have the right to withdraw your consent at any time. When you tell us you wish to exercise your right, we will stop further processing of such data. This will not affect the validity of any lawful processing of your data up until the time when you withdrew your consent. You may withdraw your consent by contacting Police Now.
Further guidance on your rights is available from the Information Commissioner’s Office (https://ico.org.uk/). You may also wish to contact Police Now (see contact details above) if you are considering how or whether to exercise your rights.
You have the right to complain to the UK’s supervisory office for data protection, the Information Commissioner’s Office if you believe that your data has been processed unlawfully.
Future changes to this privacy notice, and previous versions
We may need to update this notice from time to time, for example if the law or regulatory requirements change, if technology changes, if the Police Now scheme changes, or to make Police Now’s operations and procedures more efficient. Updated versions of our Privacy Notices will be published on our website.
This policy was last updated on 27th May 2022.