This policy describes how The Football Association Limited and other companies in The FA’s group (also referred to as "The FA", "we" or "us") will make use of your personal data when you register your interest for a vacancy at The FA or when you are applying for work with us (whether as an employee, worker or contractor).
This policy makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information about your rights and how to exercise then under the UK General Data Protection Regulation (“UK GDPR”). Further information about your rights, and how to exercise them, can be found in the “What rights do I have?” section.
The FA is a “controller” in relation to personal data. This means that we are responsible for deciding how we hold and use personal data about you.
Summary of how we use your data:
• The FA uses your personal data to evaluate your suitability and eligibility for a vacancy;
• Where relevant, data is managed via eArcu, a third party provider, to process and manage candidate applications and interest.
• We will comply with data protection law and principles, which means that your personal data will be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
What information do we collect?
We collect and process personal data about you when you interact with us and our websites and register your interest with The FA. This information includes:
• The information you have provided on your application form, to include responses to any pre application questions, title, name, address, telephone number, personal email address, current/most recent salary and salary expectations, current notice period, any reasonable adjustments required throughout the interview process, application source, cover letter and CV and any referral detail, if provided.
• This may also include any information you provide in your correspondence with us and during an interview.
We may also collect, store and use the following types of more sensitive personal information:
• Information about criminal convictions and offences.
• Information about your age, gender or identity, race or ethnicity, religion or faith, sexual orientation and disability.
• Information about your health, including any medical condition, health and sickness records.
How is your personal information collected?
We collect personal information about candidates from the following sources:
• You, the candidate
• External recruitment agencies
• Pre employment background check provider
• Disclosure and Barring Service in respect of criminal convictions
• Your named referees
How does the FA use this information, and what is the legal basis for this use?
The FA processes this personal data for the following purposes:
• to process your application;
• to verify your identity;
• to confirm your right to work in the UK;
• to communicate with you regarding your application and the recruitment process;
• to assess your skills, qualifications, and suitability for the role;
• to carry out background and criminal records checks, and to check references where applicable;
• as required by The FA to conduct our business and pursue our legitimate interests, in particular:
• to decide whether to appoint you to the role, to include processing your personal information to see whether you meet the basic requirements to be shortlisted for the role and/or invited to an interview, and following the interview to decide whether to offer you the role, and then to carry out further checks to include criminal records checks as required for the role and taking up references where appropriate;
• in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
• for purposes which are required by law to include responding to requests by government or law enforcement authorities conducting an investigation.
• To keep records relating to the recruitment process.
If you do not provide the information when requested which is necessary for us to consider your application (such as evidence of qualifications, work history or information required for a criminal records check), we will not be able to process your application or take your application any further.
Who will The FA share this data with, where and when?
We will share your personal data with other companies in The FA Group where the relevant vacancy relates to that group company.
We will manage your data with, where relevant, eArcu for the purposes of processing and managing candidate applications and interest.
Personal data may also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws.
How does The FA use sensitive personal information?
Subject to certain exceptions, the UK GDPR prohibits the processing of “special categories of personal data”, unless there are certain justifications.
We will use your particularly sensitive personal information in the following ways:
• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made to ensure an equitable and fair recruitment
• We will use information about your ethnic origin, gender, nationality, disability or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting and committing to an equitable and fair recruitment process and representation.
Information about criminal convictions
We will collect information about your criminal convictions’ history, where relevant. This will take the form of a basic or enhanced criminal records check. The type of check required is dependent on the role that you are interested in or applying for.
Depending on the role and DBS check, we are required OR entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.
For further detail, please refer to our FA Safeguarding Regulations and broader policy.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
Automated decision making - you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
What rights do I have?
You have the following rights:
• to ask us for a copy of your personal data (a “data subject access request”);
• to correct the personal data we hold,
• to delete or restrict (stop any active) processing of your personal data. 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); and
• to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format.
• to withdraw consent. When you applied for this role, you provide consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
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 to keep or have compelling legitimate interests in keeping.
To exercise any of these rights, you can get in touch with us (or our Data Protection Officer) using the details provided in the “How do I get in touch with you?” section. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred. This is the Information Commissioner’s Office in the UK.
How do I get in touch with you, or your Data Protection Officer?
If you wish to make a data subject access request, you can do so via our online form, which can be found here. We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, you can get in touch at firstname.lastname@example.org or by writing to: Data Protection Officer, Wembley Stadium, PO Box 1966, London, SW1P 9EQ.
How long will you retain my data?
Where we process personal data in connection with an application, we keep the data for up to 24 months from the date of completion of the relevant application process. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and have conducted the recruitment exercise in a fair and transparent way.
We will only keep information received in response to a criminal records check for as long as reasonably necessary and in any event for no longer than six months after completion of the relevant application process.
After this period, we will securely archive your personal information in accordance with applicable laws and regulations
If you have registered to receive job vacancy alerts from The FA, we will hold your personal data until you inform us otherwise. You can withdraw your consent at any time by contacting us on the details provided in the “How do I get in touch with you?” section or via email@example.com.