Recruitment and Employment Privacy Notice

This Privacy Notice is regularly reviewed and may be updated or revised at any time. It was last updated in October 2025.  It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

  1. Introduction
  2. What personal data do we collect?
  3. How we use personal data
  4. Legal Basis for processing
  5. Who do we share personal data with?
  6. How long do we keep personal data?
  7. Automated decisions
  8. Your rights
  9. Data Protection Officer.

Introduction

Our core data protection obligations and commitments are set out in Wigan Council Primary Privacy Notice.

This notice provides additional privacy information for Recruitment and Employment.

It is important that the personal data we hold about you is accurate and current. Please update your personal data in My Job (external link), if employed by the Council.

What personal data do we collect?

To carry out activities and obligations as an employer we process the following personal data:

  • Name and Title
  • Home Address
  • Telephone number
  • Personal email addresses
  • Date of birth
  • Gender
  • Marital status and civil partnerships
  • Recruitment records including CV, application form, references, pre employment and verification checks.
  • Employment records including your workplace, start date, job title, national insurance number, training records, reviews, professional memberships, proof of eligibility to work in the UK and security checks.
  • Bank account details
  • Salary, Pension, Tax and national insurance status information, Payroll records, Benefits, Statutory deduction information such as student loans and court orders
  • Annual leave
  • Performance information including My Time records
  • Disciplinary and grievance information
  • Photographs, CCTV footage and other information obtained through electronic means such as swipe card records
  • Information about your use of our information and communications systems
  • Health and Safety information such as accident and incident reporting
  • Details of whether you are serving or have served in the armed forces, including the area, or whether your partner or sibling(s) are serving members of the armed forces (but only where you have opted to provide this information)
  • If you are a carer (but only where you have opted to provide this information)
  • If you are care-experienced or a care leaver (but only where you have opted to provide this information)
  • Location information where you have signed up to the lone worker app (but only where you have opted to use a location-based session and that session is active).

We also process the following Special Category and Criminal Offence Data:

  • Trade union membership
  • Information about your race or ethnicity, religious beliefs, sexual orientation, any disability you have
  • Political opinions (for politically restricted posts)
  • Medical information including physical health or mental condition, sickness and occupational health records
  • Offences (including alleged offences), criminal proceedings, outcomes and sentences.

 How we use personal data

The main purposes for processing your personal data are:

  • Undertaking pre-employment and verification checks during the recruitment process
  • In the recruitment decision-making process including internal recruitment
  • Determining/reviewing the terms on which you work for us
  • Checking you are legally entitled to work in the UK
  • Paying you and, if you are an employee, deducting tax and national insurance contributions
  • Processing and liaising with your pension provider
  • Administering the contract that we have entered into with you
  • Conducting performance reviews, managing performance and determining performance requirements
  • Making decisions about salary reviews and compensation
  • Paying union subscriptions directly from your salary
  • Education, training and development requirements
  • Assessing qualifications for a particular job or task
  • Ascertaining your fitness to work
  • Managing absence
  • Gathering evidence for possible grievance, capability, sickness absence management or disciplinary hearings
  • Making decisions about your continued employment or engagement, including making arrangements for the termination of our working relationship, where necessary
  • Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work
  • Complying with health and safety obligations and public access legislation
  • To prevent fraud, including sharing and matching of personal information for the national fraud initiative
  • To conduct data analytics studies to review and better understand employee retention and turnover rates
  • Business management and planning including accounting and auditing
  • For equal opportunities and equality and diversity monitoring purposes across the employee experience
  • To support and drive inclusion across the workforce
  • Comply with legal obligations in relation to equality and diversity
  • To offer you work-related benefits and support and networking opportunities.

Legal basis for processing

The lawful bases we rely on for processing your personal data are:

  • Entering into or performing obligations under your contract of employment
  • Legal obligations
  • Legitimate interests provided that your interests and fundamental rights do not override those interests
  • Consent.

The legal obligations arise from the following (non-exhaustive) list:

  • Equality Act 2010
  • Health and Safety at Work etc Act 1974.

and to comply with disclosure of salary and tax information to HMRC or to undertake safeguarding and DBS checks.

The conditions we rely on for processing your special category data are:

  • Performing or exercising obligations or rights under employment law, social security law or social protection law
  • Where it is needed to assess your working capacity on health grounds
  • For reasons of substantial public interest, including but not limited to where it is needed in relation to exercising or defending legal rights; fraud prevention and protection of public funds; administration of justice; equality of opportunity or treatment.
  • Explicit consent. 

The conditions we rely on for processing your criminal offence data are:

  • Consent
  • For reasons of substantial public interest, including but not limited to, statutory etc and government purposes, preventing or detecting unlawful acts, protecting the public against dishonesty etc.

Who do we share personal data with?

In addition to the general reasons for data sharing described in the Council’s Primary Privacy Notice, we collect from or share personal data with the following when required:

  • referees
  • employment agencies and former employers
  • Disclosure and Barring Service
  • Complainants (e.g. service users/employees)
  • Next of kin
  • Health professionals
  • Public sources, if relevant to employment and job role
  • Government Depts and Agencies
  • Estate agents, landlords and legal professionals
  • Training providers
  • Pension providers
  • Your trade union
  • Wigan Council’s Performance & Insight Unit
  • For the purposes of the National Fraud Initiative conducted by central government under Section 33 and Schedule 9 of the Local Audit and Accountability Act 2014
  • In connection with school workforce census as provided for in Section 114 of the Education Act 2005 and the associated Education (Supply of Information about the School Workforce) (No.2) (England) Regulations 2007/2260, which affects some directly employed council staff working in education.

How long do we keep personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any future legal, accounting, or reporting requirements.

Once your employment ends we must continue to retain necessary information in accordance with our corporate records management policy to fulfil legal, statutory, regulatory and pension requirements.

Automated decisions

All the decisions we make about you involve human intervention.

Your rights

More information on how to seek advice to exercise your rights, raise a concern or complain about the handling of your personal data by the council can be found in at Wigan Council Primary Privacy Notice.

Data Protection Officer

If you wish to raise a concern or seek clarification about any aspect of this notice, please contact our Data Protection Officer. Please provide documents to prove your identity along with a description of your concern.

We will respond to all requests within one month.

If you are unhappy with the way that we handle your concern you may complain to the Information Commissioner’s Office (ICO) (external link)

Document information

Owner: Lisa Selby, Assistant Director, HR and OD

Author: Vicki Lowe, Service Lead, HR and OD

Version and date: V8.0, October 2025