1    INTRODUCTION

​​

This privacy policy informs our candidates of the types of data that Accession Therapeutics Limited and its group companies (together “Accession” or the “company”) process about candidates for potential roles at Accession and how this is kept in accordance with the applicable laws / regulations. 

​

Included within this policy are the reasons for processing candidate data, the lawful basis that permits Accession to process it, how long Accession keeps candidate data for and candidates’ rights regarding their data. 

​

This policy applies to current and former candidates for roles in Accession.

​

​

2     DATA PROTECTION PRINCIPLES 

​

 All personal data obtained and held by Accession is processed in accordance with applicable data protection laws, which means that: 

​

• processing is fair, lawful and transparent 
   

• data is collected for specific, explicit, and legitimate purposes 
   

• data collected is adequate, relevant and limited to what is necessary for the purposes of processing 
   

• data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
   

• data is not kept for longer than is necessary for its given purpose 
   

• data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage, by using appropriate technical or organisation measures 
   

• Accession complies with the relevant data protection legislation for international transfers of personal data 

​

​

3    TYPES OF DATA HELD

​

We keep a range of personal data from job applicants in order to manage and to carry out effective and efficient recruitment processes. We keep this data in restricted electronic format relating to each individual.  This data may include (but is not necessarily limited to):

​

• The information provided by the candidate in sending their CV and covering letter/application 
   

• Searches made by Accession or its agents of publicly available data sources such as LinkedIn or other public registers to check work history, certifications or qualifications etc 
   

• Any information provided during an interview or as part of technical assessment during the recruitment process 
   

• Feedback from interviewers and other assessors during the job application 
   

• Bank details (if Accession reimburses a candidate for their travel expenses) 

​

Accession may also collect, store and use the following “special categories” of sensitive personal information: 

​

• Information about a candidate’s race or ethnicity, religious beliefs, sexual orientation and political opinions if this is made known by the candidate during the recruitment process or through publicly available data sources 
   

• Information about criminal convictions and offences (if relevant to the role) 

​

​

4    COLLECTING YOUR DATA

​

You provide personal data to us directly during our recruitment or hiring process.

​

In some cases, we will collect data about you from third parties, such as from the public domain, employment agencies, information from employment background check providers, former employers and when gathering references or from criminal records checks permitted by law.

​

Should you be successful in your job application, we will gather further information from you, such as your bank details and emergency contact details once your employment begins.

​

​

5    LAWFUL BASES FOR PROCESSING

​

The law allows Accession to process candidate data for certain reasons only. The information below categorises the types of data processing that Accession undertakes and the lawful basis that it relies on. 

​

Accession has a legitimate interest to process recruitment personal data to enter into and carry out its recruitment processes which may result in an employment offer and in sending an employment contract to a candidate.

 

In some cases, Accession needs to process data to ensure that it complies with its legal obligations. For example, Accession is required to check a candidate's entitlement to work in the UK. 

​

​

6    SPECIAL CATEGORIES OF DATA

​​

Special categories of data means data relating to a candidate’s health, sexual orientation, race, ethnic origin, political opinions, religion, trade union membership, genetic or biometric data. 
 

Accession may carry out processing activities using special category data: 

​

• for the purposes of equal opportunities monitoring 
   

• to manage your access to our offices for attendance to interviews if a candidate has special needs (e.g. due to a disability) 

​

Most commonly, Accession will process special categories of data when the following applies: 

​

• candidates have given explicit consent to the processing 
   

• Accession must process the data in order to carry out its legal obligations 
   

• candidates have already made the data public (e.g. on LinkedIn) 

​

​

7    FAILURE TO PROVIDE DATA

​

A candidate can refuse to provide their personal data, although a failure to provide data may mean that Accession is unable to progress the recruitment process or make any offer of employment. 

​

​

8    CRIMINAL CONVICTION DATA

​

Accession will only collect criminal conviction data where it is appropriate given the nature of a candidate’s proposed role and where the law permits this. 

​

​

10    WHO ACCESSION SHARES CANDIDATE DATA WITH 

​

Candidate personal data may be shared internally, including with interviewers or members of the relevant team in which the role fits, heads of department, legal counsel and IT staff. This will only be done if access to the data is necessary for performance of their roles or for the legitimate operations of Accession. 

​

All candidates with access to that data will have to ensure that the data is used and processed in line with all applicable data protection legislation. 

Accession may also share a candidate’s personal data with: 

​

• our agents / professional advisors 
   

• third party contractors who provide services to Accession (e.g. visa sponsor support providers) 
   

• potential investors or acquirers 
   

• HMRC or other third parties where Accession is under a legal obligation to do so 

​​

These kinds of disclosures will only be made when strictly necessary for the purposes set out in Section 5 above. 

​

Accession may also transfer personal data to a country/countries outside of the UK or EEA. Transfers may take place where third party providers (e.g. Microsoft) store the company’s cloud data. 

​

Where Accessions share candidate data with third parties, Accession will only do this where the third party is reputable and agrees that they have appropriate technical and organisational measures in place to ensure the security of such data as required to protect the candidate’s personal data. 

​​

​

10   PROTECTING CANDIDATE DATA 

​

We take protection of candidate personal data seriously. Failure to follow Accession’s rules on data security may be dealt with through the company’s disciplinary procedure which may result in a formal warning or dismissal, depending on the severity of the failure. 

​

​

11    PROTECTING THE DATA OF OTHERS 

​

Candidates may have access to personal data of Accession or its staff during the recruitment process. The Candidate must ensure that any use of that personal data complies with relevant data protection laws. 

​

If candidates provide any third party personal data to Accession (e.g. referees etc), they warrant and represent that the relevant individual/data subject has given the candidate the right to disclose that personal data to Accession. 

​

​

12    RETENTION PERIODS 

​

The company will retain a candidate’s personal information for a period of up to 6 months after it has communicated its decision about whether to appoint the candidate to a role. 

​

Accession retains candidate personal information for that period so that it can show, in the event of a legal claim, that it has not discriminated against candidates on prohibited grounds and that the company has conducted the recruitment exercise in a fair and transparent way. 

​

After that 12 month period, Accession will securely destroy the candidate’s personal information in accordance with applicable laws and regulations unless the candidate has consented to Accession retaining those details for future job opportunities, in which case the company will retain the personal data until the candidate withdraws their consent. 

​

​

14   CANDIDATE RIGHTS 

​

As a data subject, candidates have the following rights in relation to the personal data Accession holds about them: 

​

• the right to be informed about the type of data Accession holds on them and what the company does with it 
   

• the right of access to the data Accession holds on them 
   

• the right for any inaccuracies in the data Accession holds to be corrected if they are identified 
   

• the right to have data deleted in certain circumstances 
   

• the right to restrict the processing of the data 
   

• the right to transfer certain data Accession holds on them to another party 
   

• the right to object to the inclusion of any information 

​

To exercise any of these rights or if a candidate has any queries in relation to how their personal data is process by Accession, they should contact privacy@accessiontherapeutics.com. 

​

​

15    CONSENT

 

Where candidates have provided consent for Accession’s use of their data, candidates also have the right to withdraw that consent at any time. This means that Accession will stop continuing to process that candidate data unless there is another legitimate reason to continue processing. 

​

​

16    MAKING A COMPLAINT

​

If a candidate thinks their personal data rights have been breached, candidates are able to raise a complaint with the UK’s Information Commissioner. 

​

More information on this is available here: https://ico.org.uk/make-a-complaint. 

​

​​