PRIVACY NOTICE: RIGHT TO WORK CHECKS
1. ABOUT US AND THIS NOTICE
9-2-3 Jobs Limited ("we", "us", "our") is committed to protecting the privacy and security of your personal data.
This Privacy Notice explains how we collect, use, and process your personal data when conducting mandatory Right to Work in the UK checks in relation to a conditional offer of employment or engagement.
For the purposes of English data protection law (the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018), we act as a Data Controller.
2. WHAT PERSONAL DATA WE COLLECT
To verify your legal entitlement to work in the United Kingdom, we (and our identity service provider) collect and process the following categories of personal data:
Identity and Contact Data: Your full legal name, date of birth, nationality, current residential address, email address, and telephone number.
Documentary Data: Copies of identity documents which may include your passport, national identity card, driving licence, biometric residence permit (BRP), visa, birth certificate, marriage certificate, national insurance documentation and/or Home Office share code.
Biometric Data (Special Category Data): Digital images, face scans, and liveness verification data generated when scanning photo identification (e.g., passports) to verify your facial match against your documentation.
Verification Status Records: Results and reports generated by the verification process confirming your immigration status, entitlement to work, and any associated conditions or expiry dates.
3. LEGAL BASES FOR PROCESSING YOUR DATA
Data protection law requires us to have a specific legal ground to process your personal data.
Standard Personal Data: We process your general personal data under Article 6(1)(c) of the UK GDPR(Compliance with a legal obligation). As an employment agency/employer, we are legally required under statutory immigration legislation (including section 48 of the Border Security, Asylum and Immigration Act 2025 and associated Home Office Codes of Practice) to conduct Right to Work checks prior to commencement of your work with our clients.
Biometric & Special Category Data: When processing biometric data (facial image comparison/liveness detection), we rely on Article 9(2)(b) of the UK GDPR (Necessary for carrying out obligations under employment, social security, and social protection law), in conjunction with Schedule 1, Part 1, Paragraph 1 of the Data Protection Act 2018.
4. HOW WE COLLECT YOUR DATA AND USE TRUSTID
We carry out digital identity checks through our contracted Identity Service Provider (IDSP), TrustID Limited.
TrustID acts as a Data Processor acting strictly on our instructions.
How the Process Works: You will receive an email or link directing you to upload images of your identity documents (such as your passport) and a live facial scan (selfie) directly to the TrustID platform.
Biometric Verification: TrustID utilizes automated document extraction, facial recognition, and liveness check technology to confirm that your document is authentic and matches your physical identity.
Manual Alternatives: If you are unable to complete a digital check, or prefer not to use the digital biometric route, we will conduct a standard manual Right to Work check in accordance with official Home Office guidance.
5. SHARING YOUR PERSONAL DATA
We limit access to your data to personnel who have a business need to know. We share your data only with:
TrustID Limited: For the purpose of running digital identity authentication.
The Home Office / UK Visas and Immigration (UKVI): Where verification via official share code services or the Employer Checking Service (ECS) is required.
End Clients / Hirers: Where necessary to confirm to hirers that statutory pre-engagement checks have been successfully completed;
Potentially our IT support providers, Blue Spires Solutions Ltd;
Other software service providers which help us to run our systems, such as Google and Microsoft; and
Our database provider, Zoho Corporation Private Limited.
We do not transfer your personal data outside the UK or European Economic Area (EEA) unless adequate data protection safeguards are in place.
6. DATA RETENTION
Unsuccessful Applications / Check Failures: If you do not commence work with our client, your Right to Work check records will be securely destroyed after 12 months
Successful Onboarding: If you commence work with our client, we are legally required under Home Office Right to Work regulations to retain a record of your Right to Work verification for the duration of your employment plus two (2) years after your employment terminates.
TrustID Retention: Data uploaded to TrustID is retained by them on our instructions for the minimum period needed to process the check (typically up to 14 days) before being permanently purged from their processing systems, unless extended retention is instructed.
7. YOUR DATA PROTECTION RIGHTS
Under UK data protection law, you have specific rights regarding your personal data, subject to certain legal limitations:
Information: Right to be informed about the collection and use of your data.
Access: Request a copy of the personal data we hold about you.
Rectification: Request correction of inaccurate or incomplete data.
Erasure: Request deletion of your data (where we no longer have a legal obligation to retain it).
Restriction: Request that we temporarily suspend the processing of your data.
Objection: Object to processing where we rely on legitimate interests.
Objection to use of your data for direct marketing purposes: if you let us know that you object to this use of your personal data, then we will of course stop using it for this purpose immediately.
Format: You may request the information we hold about you in a machine-readable, structured, and commonly-used format.
Complaints: The right to complain to 9-2-3. If you have a concern about the way 9-2-3 has processed your personal data, then in the first instance you may wish to make a complaint directly to us. The information set out at https://www.923jobs.com/data-protection-complaints-landing about how you can do this may assist you;
Further information about these rights generally is available at: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
We’re sure that you will understand that we may require evidence of your identity before we are able to act on any request made in relation to the above rights.
To exercise any of these rights, please contact us using the contact details in Section 8 below.
8. CONTACT INFORMATION & COMPLAINTS
If you have questions about this Privacy Notice or how your personal data is handled, please contact:
Contact Person : Helen Wright
Email Address: helen@923jobs.com
Postal Address: White Lion House, South Side, Steeple Aston, Bicester OX25 4RR
You also have the right to lodge a complaint at any time with us, using the details set out here: https://www.923jobs.com/data-protection-complaints-landing, or with the UK supervisory authority for data protection:
Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Website: https://www.ico.org.uk