Recruitment Privacy Notice
This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to you because you are applying for work with us whether as an employee, worker or contractor.
The Automobile Association Limited of Fanum House, Basing View, Basingstoke, Hampshire, RG21 4EA is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.
This privacy notice applies to personal information processed by, or on behalf of, The AA Group.
The AA Group of companies means The AA, together with any entity in which The AA directly or indirectly has at least a 50% shareholding.
We have a dedicated data protection officer (“DPO”). You can contact the DPO using the details below or by writing to the above address, marking it for the attention of the DPO.
Changes to this privacy notice
We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices.
The kind of personal data do we hold about you?
Personal information that we’ll process in connection with your application for recruitment if relevant, includes:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
- Personal details such as date of birth, marital status, national insurance number, bank account details, payroll records, and tax status information;
- Existing and former salary, annual leave, pension, and benefits information;
- Copies of driving license, passport, birth certificates, and proof of current address, such as bank statements and council tax bills;
- Evidence of how you meet the requirements of the job, including the information you have provided to us in your CV, cover letter and provided references;
- Your skills, experience, competency, and qualifications information (including any awarding body, dates, and location of study/completion);
- Employment records (including job titles, work history, working hours, training records, and professional memberships);
- Your residency and/or citizenship status, if relevant, such as your nationality, your length of residency in the UK, and/or whether you have the permanent right to reside in the UK;
- Proof of your identity and right to work in the UK, such as copies of passport, driving license or utility bills;
- Diversity and equal opportunities monitoring information – this can include information about your gender, race or ethnicity, nationality, religious beliefs, sexual orientation, political opinions, disability, and other ‘special category data
- If you contact us regarding your application, a record of that correspondence
- Video footage or CCTV images when visiting one of our sites
- Details of your use of our recruitment tools and services, such as your candidate profile and alerts for vacancies;
- The status of your application and updates on how it moves forward;
- Any information you provide to us during an interview or assessment;
- Information relating to financial checks, such as County Court Judgments (CCJs), Bankruptcies, Debt Relief Orders (DROs), Disqualified Directors and Individual Voluntary Agreements (IVAs);
- Information about your health, including any medical condition, disability status, health, and sickness records (if required); and
- Information about criminal allegations, proceedings, convictions, and offenses (if required), which may include associated documentation.
What is the source of your personal data?
We collect personal information about candidates from the following general sources:
- You, the candidate;
- Your recruitment agency;
- Your former employer(s);
- Your named referees, from whom we collect information about you, your employment history including dates, locations and job role;
- AA Group companies, if you already have worked for or provided services to them; and
- From other sources such as Fraud Prevention Agencies, Credit Reference Agencies, HMRC, DWP, DVLA, DVSA, publicly available directories and information (e.g. telephone directory, social media, internet, news articles), other organisations to assist in the prevention and detection of crime, police and law enforcement agencies.
What do we use your personal data for?
We use your personal data, as listed in section 1 above, for the following purposes:
- Assess your skills, qualifications, and suitability for a role with the AA;
- To contact you about other potential recruitment opportunities that may be of interest to you;
- Carry out background and reference checks, where applicable;
- Checking you are legally entitled to work in the UK;
- Ascertaining your fitness to work;
- Communicate with you about the recruitment process;
- To provide appropriate adjustments during the recruitment process;
- Complying with health and safety obligations;
- To review and consider appropriate workplace adjustments;
- Keep records related to our recruitment processes;
- To ensure meaningful equal opportunity monitoring and reporting;
- Comply with legal or regulatory requirements and guidance;
- Record keeping, business management, and planning, including accounting and auditing;
- To facilitate the sale of one or more parts of our business; and
- To enable other AA Group companies to perform any of the above purposes.
As part of our recruitment process, we may undertake searches and checks about your suitability for the role you apply for. We may make searches about you at Fraud Prevention Agencies and/or Credit Reference Agencies who will supply us with information, including information from the electoral register, to support our recruitment decision. The agencies will record details of the search but will not make them available for use by lenders to assess your ability to obtain credit. We may use scoring methods to assess this application and verify your identity.
Given the nature of our business, we have legal and regulatory obligations to ensure that the people we employ can be relied upon and are responsible. We therefore ask questions about any prior civil or criminal proceedings you may have been subject to and may also conduct criminal record checks with the Disclosure and Barring Service where they are appropriate to the role
Any diversity information you provide us will be treated as confidential. It will only be used for statistical purposes to ensure we remain committed to our strategy of creating an inclusive workplace.
What is the legal basis for processing your personal data?
- Where it is needed to process your application as part of the recruitment process and take steps at your request to decide whether to enter into a contract of employment with you.
- Where it is in our legitimate interests to do so, such as where we need to share your personal information with people or organisations in order to run our business or comply with guidance and recommended best practices of government and regulatory bodies, such as completing background checks and in most cases assessing your fitness to work.
- To comply with our legal obligations.
- With your consent or explicit consent, such as processing special category personal data, which may include information about your health, if you have a disability, or some criminal records information.
- For a public interest, such as processing special category personal data, for example, information about your health or criminal records (including alleged offenses).
When do we share your personal data with other organisations?
We may share information with the following third parties for the purposes listed above:
- AA Group companies and service providers;
- Governmental and regulatory bodies such as HMRC, DWP, DVLA, DVSA, the Financial Conduct Authority, the Prudential Regulation Authority, and the Information Commissioner’s Office;
- Other organisations and businesses who provide services to us such as training providers, payroll providers, pension administrators, backup and server hosting providers, IT software and maintenance providers, document storage providers, and suppliers of other back office functions;
- Credit reference agencies;
- The Disclosure and Baring Service; and
- Fraud prevention agencies.
How and when can you withdraw your consent?
Where we’re relying upon your consent to process personal data, you can withdraw this at any time by emailing HR.Talent@TheAA.com.
Is your personal data transferred outside the UK or the EEA?
We’re based in the UK, but sometimes your personal information may be transferred outside the UK and the European Economic Area. If we do so, we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.
We sometimes make decisions about you using only technology, where none of our employees or any other individuals have been involved. We’ll do this where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent.
We may do this to decide to offer you employment or employment within a specific role or section of our business where we have requirements in relation to geographical location, driving licence points and unspent convictions or Driver Certificate of Professional Competence (CPC) Digital Drivers/Tachograph Card. Applicants unable to meet these requirements would be unable to progress further in the recruitment process. Another example would be for some of our finance roles, where an applicant with a certain level of County Court Judgements would be excluded from the recruitment process. Applications that do not meet those requirements will be automatically rejected.
We may also do this using data from other parts of the AA including telematics data captured on a driving assessment exercise, including driving behaviour and location information.
You have rights in relation to automated decisions and can ask that a person reviews it by contacting HR.Talent@TheAA.com.
Do we do any monitoring, involving the processing of your personal data?
In this section, monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.
We do not undertake monitoring for the purposes of crime prevention during the recruitment process.
For how long is your personal information retained by us?
Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:
- For as long as we have reasonable business needs, such as managing our relationship with you as a candidate or employee and managing our operations;
- For a period of 12 months where you are unsuccessful in a recruitment process during which time we may contact you should additional opportunities become available which we think you would be interested in; and/or Retention periods in line with legal and regulatory requirements or guidance.
What are your rights under data protection laws?
Under certain circumstances, by law, you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information which you provided to us to another party.
Rights in relation to automated decision-making which has a legal effect or otherwise significantly affect you in particular that you can in some instances object to an automated decision and ask that a person reviews it.
You can contact us by emailing firstname.lastname@example.org to exercise any of these rights.
In relation to the processing of your personal and your data rights, you also have the right to complain to the Information Commissioner’s Office which enforces data protection laws – https://ico.org.uk/.
If you have any questions about this privacy notice, wish to exercise your rights or contact the DPO, you can contact us by going to the Contact Us section of our website or by emailing email@example.com. Alternatively, you can write to AA Limited, Fanum House, Basing View, Basingstoke, Hampshire, RG21 4EA, marking it for the attention of the DPO