Candidate Privacy Policy

At Ember, we're committed to keeping your information private and secure. This notice sets out the personal data we collect about candidates for jobs and Ember employees and what we will do with it. This applies in addition to our Customer Privacy Policy.

Who are we?

We are Ember Core Ltd, a company registered in Scotland under company number SC633049 and registered office at Argyle House, 3 Lady Lawson Street, Edinburgh, Scotland, EH3 9DR (“we”, “our”, “us”), operating under the name Ember. We're registered with the Information Commissioner's Office under number ZA575885. We are the controller responsible for deciding how we hold and use personal information about you.

You can email us at it@ember.to or write to us at Codebase Argyle House, 3 Lady Lawson Street, Edinburgh, EH3 9DR.

What information do we collect?

When you apply for a job at Ember, or let us know that you're interested in a job, we will typically collect, store and process the following categories of personal information:

• Name and contact details (e.g. address, phone number and email address)
• Work and educational history (usually on your CV)
• Location and your right to work in the UK (or other geographical region)
• Answers to application specific questions and other information provided through specific assessment tasks
• Current and expected salary, compensation and benefits information
• Current notice period and future availability
• Information available on professional networking sites or other public sources such as social media
• Information you submit through our website or by any other means – e.g. your email address if you subscribe to a mailing list

At later stages we may also collect, store and process:

• Identity documents, proof of address and address history
• Information about your health, including any medical condition, along with health and sickness records
• Details of former managers or colleagues who can act as referees
• Other information provided or observations made during interviews
• CCTV data if you visit one of our sites or buses outfitted with CCTV cameras

If we are looking to make an offer for a position at Ember we’ll also collect, store and process:

• Results of background checks from third-party providers we work with, including (where relevant) information about criminal convictions and your right to work in the UK
• References from people we contact to learn about you
• Records of communications – e.g. call recordings, emails and chat transcripts
• Bank details and other payroll/tax/pension information to enable us to pay you
• Any further data you share with us as an employee such as information relating to periods of sickness

We may also ask for some 'special category' data, such as:

• Disability and neurodiversity status
• Ethnicity
• Gender identity
• Sexual orientation
• Information about your medical history and the results of any pre-employment health checks
• Results of drug and alcohol tests we ask you to take

How is your personal data collected?

We use different methods to collect data from and about you including through:

Your active interactions with us

You may give us your personal data by filling in online forms, submitting a job application or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for a role directly
• permit a recruiter to send us your details
• enquire about a role
• take part in an interview or assessment
• give us feedback or contact us

Your passive interactions with us

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. This is explained further in our cookies policy.

Third parties or publicly available sources

We may receive personal data about you from public sources such as Google, LinkedIn and social media. We may also get personal data from various third parties including recruiters involved in your application, background check providers and credit reference agencies. In some cases, we may also collect personal information from your named referees.

How your information is used

The information we collect and process is currently used to:

• Get in touch with you during the hiring process and schedule calls, meetings, or other interview tasks: Our lawful basis is to enter into a contract with you when enquiring about or making an application for a role
• Operate our recruitment process (including via related tools for doing so): Our lawful basis is our legitimate interest in being able to coordinate the process with you
• Consider your suitability for a role you’re applying for: Our lawful basis is contractual duty to ensure you are suitable for the role
• Carry out background checks: Our lawful basis is contractual duty to ensure you are suitable for the role
• Ensure you have the right to work in the UK: Our lawful basis for doing this is to comply with the law
• Run criminal background checks (DBS checks): Our lawful basis for doing this is to comply with the law
• Pay you, verify leave requests, submit tax information to HMRC and provide a pension: Our lawful basis for doing this is to comply with the law and a legitimate business interest in verifying we are paying the correct amount for work conducted
• Conduct ongoing performance reviews: Our lawful basis is our legitimate interest in ensuring you are fulfilling your role in line with expectations

Particularly sensitive personal data, such as the 'special categories' listed above, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data. We use 'special category' data to:

• consider whether we need to provide appropriate adjustments during the recruitment process - e.g. whether adjustments need to be made during the interview
• ensure meaningful equal opportunity monitoring and reporting
• ensure you are capable of carrying out your role in a safe and suitable manner

In the case of "equal opportunity monitoring", participation is voluntary and providing this information is optional. Any information you provide will not be used in the hiring process and has no effect on your opportunity for employment.

We will only collect information about criminal convictions if it appropriate given the nature of the role and where we are legally able to do so.

Automated decision-making

We may use automated decision-making in the form of online assessments to assist our recruitment processes. These online assessments are mainly designed to assess your competency for the role you have applied for. These online assessments will produce a score based on the responses you provide, which is then used to determine whether or not to progress your application.

If you are not happy with the outcome of any automated decision we have made, you have the right to challenge this. See the “Your rights” section below for more information about how you can do this.

Who do we share data with?

As well as people working for us, we may disclose your personal data to:

• Companies that provide services to us: This includes email, telecommunications and hosting providers like Amazon Web Services, Google Cloud, Notion, Sendgrid and Twilio. We make an effort to minimise the amount of data we share, for instance sharing anonymous IDs rather than names
• Companies who run background and reference checks on our behalf
• Recruitment agencies that we engage with during the recruitment process
• Recruitment software service providers, for the purpose of processing your application, onboarding, or scheduling interviews
• Insurance companies, in the course of checking suitability for roles or providing ongoing coverage
• Law enforcement agencies and other third parties, where necessary to meet our legal obligations
• Anyone you give us permission to share the data with

We require third parties to respect the security of your data and to treat it in accordance with the law. We do not allow third parties to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions.

We may transfer your personal information outside the UK or the European Economic Area (EEA). If we do, you can expect a similar degree of protection in respect of your personal information.

How long we keep your information

As a candidate, we keep your data for at least 6 months in case we face a legal challenge about our decision. If you are unsuccessful, we will then delete some of your information but retain other data we keep for up to 6 years. In some cases, we may keep the data for longer if it's in our legitimate interest (e.g. for fraud detection) or it's required to comply with the law.

Where your data is stored

In some cases, the data we collect from you may be transferred to and stored by countries or organisations outside the UK or the EEA. In these cases, we'll make sure that the European Commission says the country or organisation has adequate data protection, or we’ve agreed to standard data protection clauses approved by the European Commission with the organisation. Contact us if you'd like a copy of the relevant data protection clauses.

Your rights

Your personal data is protected by legal rights, including your rights to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we’re lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please do note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which we will notify you of, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• Request the transfer of your personal data to you or to a third party. We’ll provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy
  • Where our use of the data is unlawful but you don’t want us to erase it
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

You won’t have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data isn’t disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we’ll notify you and keep you updated.

For more information or to exercise your data protection rights, please email it@ember.to.

How to complain

If you have a question or want to complain about how we've used your personal data, email us at it@ember.to. If you're not happy, you also have a right to complain to the data protection supervisory authority in the EU country where you live or work, or where you think a breach happened. The Information Commissioner's Office (ICO) is the UK regulator.

Changes to this notice

We may up date this notice from time to time. Any changes will be posted on this page and, if appropriate, sent to you by email.