Guidance

Civil Service HR Talent Privacy Notice

Updated 27 July 2023

Civil Service Talent aims to develop a strong and diverse pipeline of inspiring, confident and empowering leaders to help shape the future of the Civil Service.

Our role is to attract, develop and retain talented people from inside and outside of the Civil Service, so that they can deliver the work of government. We do this by improving talent capability across government departments and functions, running excellent recruitment campaigns, delivering accelerated development schemes and wider development offers and championing activities to make the Civil Service a more diverse and inclusive employer.

This notice applies to Senior Civil Servants (SCS) and civil servants of lower grades that apply for schemes, who are on schemes or scheme alumni or civil servants otherwise engaging with talent management activities, as well as external candidates applying to the Senior Civil Service. This notice sets out how we will use your personal data, and your rights.

It is made under Articles 13 and/or 14 of the General Data Protection Regulation (GDPR).

The broad areas that we are processing data fall under:

1) SCS recruitment
2) SCS talent capability monitoring & succession planning
3) Civil Service development and accelerated development programmes, and attraction and recruitment activities associated with these, including diversity of panels
4) Talent management engagement
5) Diversity monitoring for all the groups affected by the above

In exceptional situations, we would also be able to share your name, professional history and contact details with HR teams in government departments in order to resource critical or emergency work across government.

Your data

We will process the following personal data in relation for all the activities above. More details about additional data collected is below:

• name
• job Title
• department
• profession
• grade
• function
• contact Details
• location

Purpose

For all of CSHR’s Talent’s functions, we are processing your personal data:

• to identify particular skills and experience to aid in workforce planning and facilitate in the targeting of talent management or other development initiatives, including recruitment
• for legal, audit and statistical purposes
• to provide background information in preparation of honours citations for the Cabinet Secretary
• to support talent moderation conversations
• to evaluate and review policy decisions and assess impact
• to develop and manage the talent of Civil Servants across departments and functions

SCS recruitment

This part of CS Talent is responsible for the recruitment and selection of individuals to fill all permanent secretary roles and some Director General roles across government.

In relation to SCS internal and external recruitment, we are processing your personal data:

• to identify individuals with particular skills and experience to aid in workforce planning and facilitate in the targeting of talent management or other development initiatives, including recruitment
• to support selection decisions during recruitment campaigns
• to include ‘near miss’ candidates who may be contacted for similar roles and development opportunities
• to identify candidates for search competitions
• to prepare employment contracts
• to inform the Cabinet Secretary in briefings on current and previous Permanent Secretaries and current and previous Permanent Secretary competition applicants
• to update the Senior Leadership Committee and Cabinet Secretary on Director General competitions
• to update CSHR and recruiting departments on candidate applications

Data

In relation to SCS recruitment, we will process the following personal data in addition to those identified above:

• location
• working pattern
• CV (including educational, professional background)
• immigration status
• media assessments results and reports
• professional and personal referee details
• employment references
• security clearance
• supporting statements
• career aspirations
• disability Confident scheme and reasonable adjustment requirements
• nationality
• psychometric assessments of individuals including scores and reports
• current and/or previous pay and salary
• staff engagement exercise results and reports
• declared potential conflicts of interest
• written correspondence in relation to application

In relation to specialist roles with professional functions, we will process the following personal data :

• membership (or otherwise) of professional bodies

In relation to high sensitivity roles, we will process the following personal data:

• membership (or otherwise) of a trade union; and
• political opinions

SCS talent capability monitoring & succession planning

The purpose(s) for which we are processing your personal data:

DG and Director biographies are collected annually.

These biographies are submitted annually and may be shared with the Senior Leadership Committee (for DGs), the Leadership and Talent Board (for Directors), the wider Permanent Secretary community and relevant HR colleagues for the purposes of:

• talent moderation and discussion
• succession planning for DG and Permanent Secretary roles
• development planning and related activities
• to inform briefings for career conversations and 1:1 meetings

Data

In relation to SCS talent capability monitoring we will process the following personal data:

• photographs;
• working pattern;
• your profession/career anchor and the profession of your current role;
• the date you started your current role and when you were promoted to your current grade;
• qualifications;
• self declared skills and development needs;
• career history and future intentions;
• learning and development information, including but not limited to coaching, mentoring, and development scheme participation
• previous and current talent markings.

Civil Service accelerated development scheme and wider offers and their selection activities

Accelerated development schemes designed to identify and develop a strong, robust and diverse pipeline to the most senior roles in government.

In relation to Civil Service Accelerated Development Schemes, we are processing your personal data:

• for selection and management of accelerated development schemes, external schemes and wider offers across government
• for signposting other development offers to individuals engaging with the schemes either as part of cohorts or applicants
• to engage with alumni of the schemes and of the Civil Service
• to enable access to targeted events and support for participants, applicants and alumni of the schemes, and “near-misses”
• to evaluate and review activities undertaken as part of the above
• external schemes and selection activities to departments, functions, networks and governance bodies
• to arrange mentoring and sponsorship for participants
• to report on the impact and outcomes of accelerated development schemes
• aid decision making in departments, we may share your details about applicants, and successful and unsuccessful candidates, and past and current scheme members, including on META and DELTA.

Data

In relation to Civil Service Accelerated Development Schemes, including applicants, participants and alumni, we will process the following personal data:

• photographs
• working pattern
• staff number
• year joined Civil Service
• CV, including educational and professional career history
• career aspirations
• Personal Development Plans
• individual leadership assessment results and reports
• national identity
• selection assessments of individuals, including psychometrics
• previous development undertaken
• strengths/development areas
• previous and current talent markings
• case study profiles (where provided)
• testimonials (where provided)
• line manager’s details
• scheme eligibility
• attendance at scheme events/ modules/ catch-ups and engagement with the activities
• workplace adjustments
• learning and development information, including but not limited to sponsor, coach, mentor, professional qualifications and accelerated development scheme participation
• scheme(s) you have taken part in
• interaction and engagement with the network

Where you did not provide your personal data to us, it was obtained by us from: publicly available information; or provided to us by another team or government department.

Talent management engagement

For the purposes of arranging events and sharing good practices across government, we process the following data from departmental talent leads, including, but not limited to, HR directors and Heads of Talent Leads:

• name
• contact details
• location
• grade

These details are updated on a regular basis by CS Talent. The details may be shared with Heads of Talent across the Civil Service for the purposes of:

• identifying and sharing good practices
• inviting and collating data from across the Heads of Talent Community

The information may also be shared with other parts of CSHR.

Diversity monitoring for all the groups affected by the above

This activity is conducted within and across each of the areas described in section 1-4 above. The purpose of the diversity monitoring of activities and groups are to:

• monitor diversity for all recruitment, accelerated development schemes and offers, and leadership development activities, including diversity of interview panels
• identify gaps and allow offers of additional support to specific groups
• reporting
• ensure that there are no adverse effects on any particular groups of CS Talent management activities.

Data

In relation to diversity monitoring across all of the groups affected by the above, we will process the following data:

• disability
• ethnicity
• gender
• age
• working pattern
• religious, philosophical and other beliefs
• nationality
• caring responsibilities
• sexual orientation
• socioeconomic background

The legal basis for processing your personal data

The legal basis for processing your personal data in relation to serving Civil Servants or job applicants is because it is necessary to comply with a legal obligation placed on us as the data controller. This includes compliance with the Constitutional Reform and Governance Act 2010, and the Equality Act 2010, to demonstrate fair, open and on merit recruitment. The system also needs to process and take a record of applicant progress and performance through recruitment stages.

The legal basis for processing your personal data in relation to identifying talent, serving Civil Servants or job applicants is also because it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller. In this case, that is to build a robust and diverse pipeline to the most senior and critical roles in the Civil Service. It is also to effectively deliver our public services and the Government’s agenda.

The legal basis for processing your personal data in relation to serving Civil Servants or job applicants is because it is necessary:

• for the performance of a contract to which you are a party (for example an employment contract)
• in order to take steps at your request prior to entering into a contract (for example an application for employment or pre-employment checks).

It is necessary to comply with a legal obligation placed on us as the data controller - we are required to report on equality of opportunity; and onboarding processes have specific requirements.

The legal basis for processing your sensitive personal data

Sensitive personal data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

The legal basis for processing your sensitive personal data in relation to serving Civil Servants or job applicants is because:

• it is necessary for the establishment, exercise or defence of legal claims (for example, in relation to employment tribunal claims)
• it is also necessary for the purposes of performing or exercising our obligations or rights as the controller, or your obligations or rights as the data subject, under employment law, social security law or the law relating to social protection
• it is necessary for protection under the Equality act 2010 to prevent discrimination in employment
• processing is necessary for reasons of substantial public interest for the exercise of a function of the Crown, a Minister of the Crown, or a government department. In this case, CS Talent undertakes development, requirement and talent management activities for civil servants across government
• processing of data concerning ethnicity, religious or philosophical belief, health including disability or sexual orientation is necessary for the purposes of identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with a view to enabling such equality to be promoted or maintained. Diversity data is collected to review equality of opportunities for those applying for roles in the Civil Service
• it is also necessary for statistical purposes, and it is in the public interest

The legal basis for processing your sensitive personal data in relation to identifying potential talent, is because:

• it is necessary for reasons of substantial public interest (for the exercise of a function of the Crown, a Minister of the Crown, or a government department). In this case, it is to build and maintain a robust and diverse pipeline to the most senior and critical roles in the Civil Service and effectively deliver our public services and the Government’s agenda
• it is also necessary for archiving purposes, scientific or historical research purposes or statistical purposes, and it is in the public interest. Analysis of applications and recruitment outcomes (including online tests), impact on protected groups, timescales for recruitment, and other research may be carried out

The legal basis for processing by us of personal data relating to criminal convictions is because it is necessary for reasons of substantial public interest (for the exercise of a function of the Crown, a Minister of the Crown, or a government department). That is to ensure that public sector employees will meet the required standards of propriety and conduct.

The legal basis for processing your sensitive personal data in relation to The Civil Service Alumni Network or photographs is because you consent to us doing so.

Recipients

For all purposes, as your personal data will be stored on our IT infrastructure, it will also be shared with our data processors who provide email, and document management and storage services to us.

We may share personal data in relation to the SCS recruitment, SCS talent capability monitoring, Civil Service accelerated development schemes, departmental HR and talent contacts, and the data of participants on META and DELTA to the following:

• departments, functions, or professions;
• a third party mailing service provider.

The data of departmental contacts and the data of case study participants may be shared with staff across the Civil Service.

The data of applicants for SCS campaigns may be shared by us with:

• external assessment firms (where you apply for a job and are asked to sit an assessment);
• recruitment competition panels (where you have applied for a job);
• Civil Service Commission (for oversight of whether competitions are open and on merit);
• external executive search firms and their service providers (where we commission them to identify talent on our behalf); and
• our Applicant Tracking System supplier, and their hosting partner (where you apply for a job) our Customer Relationship Management software supplier.

The data of applicants for - and participants on - accelerated development schemes may be shared by us with:

• accelerated development schemes learning providers (where you join such schemes);
• providers of selection and feedback services such as 360 degree feedback
• speakers at events (for example, where biographies of attendees are shared with SCS hosting small breakfast sessions for alumni);
• a database and web application to keep track of individuals will be hosted on the GDS Platform as a Service (PaaS)
• your mentor, sponsor, mentee, sponsored individual as part of a mentoring or sponsorship programme; and
• participants on the same accelerated development scheme as you, and staff on other schemes within your function/profession and department

The biographies of Directors and DGs will be shared with our Senior Leadership Committee, Leadership and Talent Board, relevant wider Permanent Secretaries, with relevant HR colleagues in your department, function and Civil Service Talent or DG Workforce colleagues as part of recruitment, succession planning and talent development and assessment moderation processes.

The data of alumni of accelerated development schemes may be shared by us with:

• speakers at events (for example, where biographies of attendees are shared with SCS hosting small breakfast sessions for alumni).

The data of interviewers for the FLS and SLS may be shared by us with:

• delivery partners
• training providers

Retention

Your personal data will be kept by us for:

• a maximum of two years (Selection/Recruitment Data)
• a maximum of 18 months from the last point at which you give your consent, reviewed every year (Schemes Alumni beyond the five year point)
• a maximum of five years (all other data)

Automated decision making

Your personal data may be subject to automated decision making if you make an application where online psychometric tests are used.

Decisions made on who to invite to later stages of Accelerated Development Schemes may be based on automated scoring and sifting processes. In addition, test scores and other applicant data are regularly captured for statistical and research analysis purposes. Your score is calculated from the responses you give during a test, and no other information about you is used. The score may be a percentage or percentile (your score compared to other applicants). A minimum percentage or percentile requirement may be recommended to pass, and if your score is lower than this, you may be rejected and your application will not be considered further.

Your rights

You have the right to request:

• information about how your personal data is processed, and to request a copy of that personal data
• that any inaccuracies in your personal data are rectified without delay
• that any incomplete personal data is completed, including by means of a supplementary statement
• that your personal data is erased if there is no longer a justification for them to be processed
• in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted
• a copy of any personal data you have provided, and for this to be provided in a structured, commonly used and machine-readable format

In relation to alumni data and photographs, you have the right to withdraw consent to the processing of your personal data at any time. If you withdraw your consent, we will not use photographs from that point forward, however physical or digital copies beyond our control may continue to circulate.

In relation to online psychometric tests, you have the right, in relation to automatic profiling, to obtain human intervention in the outcome, to express your point of view, and to contest the decision reached by automatic profiling.

• You have the right to object to the processing of your personal data.

International transfers

As your personal data is stored on our IT infrastructure, and shared with our data processors who provide email, and document management and storage service to us, it may be transferred and stored securely outside the European Economic Area. Where that is the case it will be subject to equivalent legal protection through the use of Model Contract Clauses.

Where your data is shared with our mailing list management supplier, it may be transferred outside the European Economic Area. Where that is the case it will be subject to equivalent legal protection through the Privacy Shield scheme.

Complaints

If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113

Email: casework@ico.org.uk

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

Contact details

Cabinet Office is the data controller for your account details, and for any applications you have not yet submitted.

Cabinet Office and the department you apply to are joint data controllers for your personal data within your submitted applications.

You can contact the Civil Service Talent team by email: civilservicetalent@cabinetoffice.gov.uk

The contact details for Cabinet Office’s Data Protection Officer (DPO) are:

Stephen Jones
DPO
Room 405
Cabinet Office
70 Whitehall
London
SW1A 2AS

Email: dpo@cabinetoffice.gov.uk