Privacy Policy

Effective date: March 05, 2019

This privacy notice (“Notice”) describes the policies and procedures relating to the use of personal data provided by candidates applying to be a special adviser to the Government by way of the Conservative and Unionist Party, commonly known as the Conservative Party (“Party”),as advertised on www.spadjobs.uk (“Site”).  

Candidates may submit applications for positions with the Party and/or Government via email to apply@spadjobs.uk and submit requests for further information at info@spadjobs.uk. These email addresses are managed by Hanbury Strategy and Communications Limited (“Hanbury”,“we”, “us” or “our”) on behalf of the Party.  

Hanbury will assess applications on behalf of theParty and may invite candidates to attend a first stage interview, or series of interviews, by telephone, online or in-person (“Stage One”).  Hanbury may then present candidates, in its discretion, who are successful at Stage One to the Party and Government, which will conduct its own assessment and interview process (“Stage Two”) to determine whether a candidate is suitable for a special adviser role.  

This Notice describes how Hanbury will collect, store and process personal data during Stage One of the recruitment process.  This Notice does not apply to any processing of candidate personal data undertaken by the Government or the Party during Stage Two of the recruitment process or during a successful candidate’s engagement as a special adviser. The Government or the Party will provide a separate notice for such processing of candidate personal data.  

It is important that you read this Notice together with any other notice or statement provided so that you are fully aware of how and why your personal data is processed.

A.   General

For the purposes of data protection law, the Party and Hanbury are joint controllers of candidate personal data collected, stored and processed during Stage One of the recruitment process.  This means that, under law, the Party and Hanbury jointly determine the purposes and means of processing candidate personal data.  

The Party is the sole controller of candidate personal data it collects, stores and processes during Stage Two of the recruitment process.  

The Party is Registered as a political party with the Electoral Commission under registration PP52 and a Registered DataController with the Information Commissioner’s Office (ICO) under registration number Z5909711.

Hanbury is a private limited company (company number: 10361418) and a Registered Data Controller with the ICO underregistration number ZA297067.

Please direct any questions or comments about this Notice or the privacy practices of the Party or Hanbury to:

The Party:

  • By email: compliance@conservatives.com
  • By phone: +44 (0)20 7984 8005
  • By post: Compliance Department, Conservative Campaign Headquarters, 4 Matthew ParkerStreet, London, SW1H 9HQ

Hanbury:

B.    What is“personal data”?

The term “personal data” as used in this Notice shall mean any information that identifies a natural person, directly or indirectly, by reference to an identifier such as name, identification number, location data, online identifier or one or more factors specific to a natural person.

Although not requested, “personal data” may include special category personal data, such as personal data revealing racial or ethnic origin, health, political opinions, religious or philosophical beliefs, trade-union membership or sexual orientation.

C.   What personal data does Hanbury collect?

When applying for a role via the Site, a candidate may provide personal data in his or her curriculum vitae, covering letter or application form, during an interview and/or when corresponding with Hanbury by post, phone, email or otherwise. Such personal data provided may include:

  • identity data, including full name, gender, date of birth and marital status;
  • contact details, including email, home and/or work address and telephone number;
  • employment history;
  • education history;
  • qualifications, skills, experience and training;
  • current remuneration and other benefits;
  • details of employment or educational referees; and
  • other information contained in a candidate’s application or that he or she choose to provide.

Hanbury will process special category personal data that a candidate includes in his or her application or otherwise provides, such as his or her disability status or other health information, racial or ethnic origin, political opinions, or religious or philosophical beliefs.  

Hanbury will not contact a candidate’s references or undertake any background checks relating to spent/unspent criminal convictions or a candidate’s right to work in the UK.  Such checks will be undertaken by the Party and/or Government, as required.

D.   Purpose for processes personal data

Hanbury will process candidate personal data for the following purposes as necessary for the legitimate interests of Hanbury and/or the Party (provided such interests are not overridden by a candidate’s interests or fundamental rights):

  • to manage the recruitment process, assess and confirm a candidate’s suitability for the available role of a special adviser to the Government;
  • to recommend a candidate’s application and to transfer data from Hanbury’s system to the Party in the event of a successful application;
  • to contact and correspond with a candidate regarding his or her application;
  • to resolve disputes and to respond to and defend against legal claims; 
  • as part of Hanbury’s efforts to keep systems safe and secure;
  • to comply with applicable law, for example, in response to a request from a court or regulatory body, where such a request is made in accordance with the law;
  • to administer internal administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
  • to reimburse a candidate for certain costs incurred related to his or her application for a position, for instance travel costs associated with travelling to and from his or her interview (if applicable).

Hanbury may also process a candidate’s personal data in order to protect his or her vital interests or the vital interests of another person, including (without limitation) if Hanbury has significant concerns about a candidate’s health and/or wellbeing.

E.   Disclosure of personal data

All candidate applications, supporting documents and any personal data are stored on Hanbury’s systems.  

Hanbury will share the application, supporting documents and any personal data relating to candidates who are successful at Stage One of the recruitment process, with the Party. In addition, at the request of the Government or the Party, Hanbury will share the applications, supporting documents and any personal data of all or selected candidates (whether or not successful at Stage One), with the Government or the Party.

Hanbury will not sell any candidate’s personal data. In addition, Hanbury will not hire out or pass on a candidate’s personal data to third parties, except in the situations provided for in this Notice or unless a candidate provides his or her prior consent.  Hanbury may share personal data with:

  • outsourced service providers or suppliers;
  • data centre providers and web hosting providers;
  • another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event.  In the case of a merger or sale, candidate personal data will be permanently transferred to a successor company.  If a change happens to our business, then the new owners may use candidate personal data in the same way as set out in this Notice;
  • public authorities as required by law; and
  • advisors, if required, in order to receive legal advice.

Hanbury will only transfer candidate personal data to trusted third parties who can: (1) provide sufficient guarantees of their technical and organisational security measures governing the processing of personal data; and (2) demonstrate a commitment to compliance with those measures.  Hanbury does not allow third-party service providers to use personal data for their own purposes and only permit them to process personal data for specified purposes and in accordance with Hanbury’s instructions.

Where third parties are processing candidate personal data on Hanbury’s behalf, they will be required to agree, by contract or other wise, to process candidate personal data in accordance with applicable law.  This contract will stipulate, among other things, that the third-party and its representative shall act only on Hanbury’s instructions, or as permitted by law.

F.   International transfer of personal data

Hanbury does not transfer candidate personal data outside the European Economic Area (“EEA”).

G.  Retention of personal data

Hanbury will store candidate personal data for no longer than is necessary for the purpose for which such personal data is processed.  

If a candidate is unsuccessful, Hanbury will retain his or her personal data for the duration of the recruitment process plus an additional 12 months thereafter. Please note, however, that Hanbury may store candidate personal data as necessary to comply with its legal obligations, resolve disputes and enforce its rights.

H.   Data subject rights

In certain circumstances candidates have rights under data protection law in relation to their personal data – specifically the right to:

  • request access to personal data;
  • request correction of personal data;
  • request erasure of personal data;
  • object to the processing of personal data;
  • request restriction of processing personal data; and
  • request transfer of personal data to a third party.

To exercise these rights, please contact Hanbury using the contact details provided in Section A above.

If the request is made by letter, please provide your name, address, email address and detailed information about the personal data you would like to update, modify or delete or any other changes you would like to make, or right you would like to exercise.

We aim to respond to requests made by you within one month but may extend that period by two further months where necessary.

We will not charge a fee for you to exercise any of the rights listed above, but reserve our right to charge a reasonable fee, or to refuse to act on requests which are manifestly unfounded or excessive.

Where you believe that we have not complied with our obligations under this Notice or European data protection law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK’sInformation Commissioner’s Office.

I.     Changes to the Notice

We keep this Notice under regular review. This version was last updated on the date set out at the top of the page.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the recruitment process.