Employment applicant privacy notice

14 October 2022
This Privacy Notice tells you how PRS for Music Limited ("PRS for Music", "we" or "us") process your personal data.  It also describes your data protection rights, including a right to object to some of the processing which PRS for Music carries out. More information about your rights, and how to exercise them, is set out in the Your Choices and Rights section.

We also may provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information. 

This Privacy Notice applies to all applicants for employment with PRS for Music, and, where applicable, to applicants for either temporary agency positions or consultancy positions with PRS for Music. 

What Personal Data We Collect

We may obtain your personal data because you have applied for a position with PRS for Music (either directly or through a recruiter). This personal data includes, but is not limited to your:

• Personal details such as your name, address, phone number, date of birth, email address, gender, socio-economic background (including place of birth), photo, nationality, immigration status, and information about your entitlement to work;
• Application related information such as your interests and aspirations including salary expectations, willingness to relocate, employment history, communications with us about the application and process, voice and video recordings, former employer(s), reason for leaving, reason for seeking employment with PRS for Music, current notice period, name of the employee referring you, academic background (including professional qualifications and education history), Curriculum Vitae (CV), cover letter, background screening information if relevant and bank account information if we re-imburse expenses; and
• Sensitive information such as information about your health and disabilities where we need to make any required adjustments to the recruitment process, equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, trade union membership (where applicable) and religion or belief.

We will hold, use and process that personal data in accordance with the terms of this Policy. 

We collect most of this information from you directly. For example, data is collected through our application portal and CVs; from correspondence with you; or through interviews, meetings or other assessments. We also collect some information about you from other people (e.g. recruiters, referrals), your referees or organisations (e.g. from LinkedIn if you choose to connect us with your LinkedIn profile; where applicable, we also collect data from our third-party background screening provider during the pre-employment screening process). 

Why We Collect, Use and Store this Personal Data

We have to have a legal basis to process your data. We explain each of these legal bases below. We also set out the purposes for which we process your data. For each purpose, we explain the lawful basis for that processing, the processing operations that we carry out and the categories of data that we process. 

Legal basis

Consent – sometimes we ask for your consent to use your data.  

Legitimate interest – we may process your data where this is necessary for us to achieve a legitimate purpose, or where this is necessary for someone else to achieve their purpose, as explained in Purposes below.   

Legal obligation – we have obligations to comply with legal and regulatory requirements under UK laws. In certain cases, we have to use your data to meet these obligations. 

Purposes

We may process your personal data for the following purposes: 
As required to operate our business and to pursue our legitimate interests in order to: 

verify information:

• we have an interest in carrying out appropriate checks to verify the information provided by candidates. We verify the details you have supplied and, where applicable, conduct pre-employment background checks; 
• we use your personal identification information and application related information for this;
• this information will be shared with companies who host our recruitment portal and systems and with background screening companies. Where we check references or previous employment and education, we disclose the fact that you have applied to us to educational institutions and to previous employers. 

process your application:

•  we collect and use your personal data so we can process your application and make informed decisions on recruitment and ensure your suitability for the role. We store, and where needed, update, your personal information to make informed decisions on recruitment and assess your suitability for the role, to communicate with you about your application, to respond to your enquiries and schedule interviews, and to reimburse you for any agreed expenses incurred in the application process; 
• we file applicants for manual review in the event of an application entry that indicates no right to work or insufficient qualifications for the post advertised at the initial stages of the application process in order to manage the volume of applications received; 
• to do this we use your personal identification information. If we need to make adjustments for you during the recruitment process, we process special category data for this purpose; and
• this information will be shared with companies who host our recruitment portal and systems. If we re-imburse expenses, we share information with financial service providers. 

improve our recruitment processes and activities:

•  we have an interest in improving our recruitment processes and to monitor compliance with our internal policies. To achieve this, we analyse your data and compare it to past recruitment processes; 
• we use your personal identification and application-related information for this purpose; 
• this information will be shared with companies who host our recruitment portal and systems.

protect our business interests:

•  we have an interest in protecting our legitimate business interests and legal rights including but not limited to, use in connection with legal claims, compliance, auditing, regulatory investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and ethics and compliance reporting requirements;
• our business interests can sometimes involve undertaking mergers, acquisitions, reorganisations or disposals, as permitted/required in accordance with applicable law;
• we also have an interest in analysing and monitoring the diversity of the workforce in accordance with applicable laws including, for example, compliance with equal opportunity employment laws; 
• to do this, we store, use and may transmit your personal identification, application-related information and sensitive information; and
• this information will be shared with companies who host our recruitment portal and systems. Information used for diversity monitoring will be shared with a specialist company that advises us on diversity.  We share information with legal and other advisers if there are investigations or potential claims.

monitor diversity & inclusion

•  you may voluntarily provide information to assist us to monitor diversity and inclusion, and to help us to promote equal opportunities. This information will be treated separately to your application.
• we use voluntarily provided personal details, such as gender and socio-economic background, and sensitive information for this; and
• this information will be aggregated and anonymised prior to any analysis.

In order to comply with applicable laws in order to:

• use your data to comply with legal, regulatory and other requirements under UK laws by analysing and possibly transmitting your personal information; 
• provide reasonable adjustments as required under law; 
• to do this we use your personal identification information and application-related information; and
• this information will be shared with companies who host our recruitment portal and systems.  
  
  

We may also ask for your consent to:

verify information: 

•  with your consent, we will carry out certain verification and staff background checks where this is required in connection with your role (for example, checking for driving endorsements where you will have access to a company vehicle);
• we use your personal identification and application-related information for this; and  
• this information will be shared with companies who provide background checking services. 

keep in touch

•  with your consent, we use your data to contact you about future career opportunities at PRS for Music and PRS for Music Members Benevolent Fund. This includes storing your data and keeping it up to date and using it to contact you; 
• we use your personal identification and communication information and application-related information for this; and
• this information will be shared with companies who host our recruitment portal and systems.  

Where we do process data based on consent, your consent can be withdrawn at any time by contacting ~recruitment@prsformusic.com or by managing your preferences in the Candidate Dashboard on our PRS for Music career portal.

If it is mandatory for you to provide data for these purposes, we will make this clear at the time the data is collected and will also explain what will happen if you do not provide the data.

More information about Verification and Staff Checks

For some positions, it will be necessary for us to verify the details you have supplied (for example in relation to your identity, academic credentials, professional credentials or your employment history), to conduct pre-employment background checks (for example, in relation to previous criminal convictions or financial standing) and/or to check for driving endorsements where you will have access to a company vehicle.  The level of required checks will vary by position and will usually be conducted at as late a stage as is practicable in the recruitment process and often only after you have been selected for the position. If your application is successful, we will provide further information about the checks involved and will obtain any necessary consent prior to completing such checks. 

How We Share Your Personal Data

We may share some of your personal data with other entities in the PRS for Music corporate group, for recruitment purposes and only with your consent.

Your personal data will also be shared with companies providing services under contract to PRS for Music such as technology services including help desk providers, IT hosting and/or IT maintenance providers, administration and analysis, as well as other agencies under contract to PRS for Music as part of the recruitment process. When we share your data with these companies, we have explained this according to each purpose above.

Your personal data also will be shared with government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.

In the event that a PRS for Music business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.

Where we transfer your personal data

We also transfer your personal data to some vendors which host or access personal data outside of the UK in which case we take steps to ensure your data is adequately protected.  If information is transferred outside the United Kingdom, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision under the United Kingdom adequacy regulations, data is adequately protected by UK Information Commissioner approved standard contractual clauses or a vendor's Processor Binding Corporate Rules. 

Your Choices and Rights

You have the right to ask PRS for Music for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine-readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to PRS for Music processing your data, this will not affect any processing which has already taken place at that time.

You can get in touch with us to exercise any of the rights listed above by using the details set out under the 'Contact Us' section, below.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority.  In the UK, this will be the Information Commissioner.

Where we collect personal data to administer a contract with you or to comply with our legal obligations, this is mandatory and we will not be able to manage the application/ employment relationship without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to participate in certain programmes or systems, where the information is needed for those purposes.

Retention of your Personal Data

We will retain your personal data only for as long as we need it for PRS for Music's legitimate interest in accordance with applicable law, for the purposes of the recruitment process and, once this process is finished, for an appropriate period to be able to deal with any legal claims linked to the application process. 

Where you application is successful, personal information you provide during the application process will become a part of your employee file and may be used later for the management of the employment relationship. Your recruitment records are generally kept for 6 years after the end of your employment with PRS for Music and as detailed in our employee privacy notice. 

Where your application is unsuccessful, your details will be deleted 9 months from the date we receive your application. If you have agreed for us to keep you updated about future recruitment opportunities, we will retain your personal data (limited to the information required for this purpose) until you withdraw your consent. 

Updates to this Privacy Notice

This Privacy Notice may be updated periodically. We will update the date at the top of this Privacy Notice accordingly and encourage you to check for changes, which will be available at prsformusic.com/about-us/working-for-us. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this Privacy Notice, as required by applicable law. 

Contact Us

If you have questions about this Privacy Notice or wish to contact us for any reason in relation to our personal data processing, please contact us at dataprotection@prsformusic.com.