Safehire.ai Ltd (Safehire) has developed a software platform that provides a customer with a means by which to undertake Surface and Dark Web searches against potential and existing employees, contractors, volunteers, and other associated persons for the purposes of compliance with applicable laws and regulations, risk management, and internal due diligence.

Prior to using the platform, it is important that you take steps to ensure compliance with your obligations under Data Protection Laws as defined and outlined within the Safehire’s Product Terms & Conditions. We have set out below some key points to consider but progressional advice should be sought as you feel necessary to ensure compliance.

Update Recruitment Policies and Associated Privacy Notice(s)

Prior to using the platform it is important that you:

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• update your relevant policies to ensure compliance with Data Protection Laws, and
• provide appropriate information to the individuals to be searched regarding the intended use of the platform and the processing of their personal data. </aside>

In the context of pre-employment screening, the following wording, tailored appropriately, may be added to your Recruitment Policy:

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“As part of the shortlisting process, we will consider carrying out an online search on shortlisted candidates as part of our due diligence. This may include using the online platform provided by Safehire.ai Ltd to undertake Surface and Deep Web background checks on shortlisted candidates for purposes including but not limited to compliance with applicable laws and regulations (such as safeguarding obligations, including those referenced in the UK Department for Education’s statutory guidance: "Keeping Children Safe in Education" as updated from time to time), risk management, due diligence, and internal policies. This may help to identify any incidents, issues or concerns that are publicly available online, which we may want to explore with an applicant at interview. This forms part of our wider [safeguarding] due diligence which aims to prevent and/or deter individuals who may be unsuitable to work [with children from working in a school environment/within the organisation given the nature of the work concerned/[tailor as appropriate to the organisation]].”

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IMPORTANT: This is suggested wording only and should be tailored to reflect the organisation’s operations. It should be provided to candidates, along with other fair processing information, in good time before any online checks take place.

In addition, relevant privacy notices should be updated to reflect the intended use of the platform and the lawful basis for processing associated personal data. This should be provided to candidates in advance of any checks. If explicit consent is relied on, this should be sought from the candidate and received in advance.

To be clear, it is your responsibility to ensure that you are complying with all Data Protection Laws.

Consider who will have access to the platform and when searches will be carried out

• Pre-employment online searches, including searches utilising the platform, should only be carried out as part of the shortlisting process – i.e., on shortlisted applicants; not on all applicants that apply for a position.
• Searches should be carried out in advance of interview so that any identified issues or incidents can be raised with the applicant during the interview, if felt necessary and appropriate.
• To minimise the risk of discrimination and/or unconscious bias, where possible, the initial search should be carried out by a member of staff not directly involved in the recruitment decision-making process.
• It is important that the individual carrying out the search understands its purpose and the associated parameters. Relevant red flag information can then be provided to those making selection decisions to inform those decisions and the approach to be taken at interview. Further guidance on how to respond to a Red Flag report can be found here 🇬🇧 Safehire.ai | Red Flag Guidance (UK)

Further detail regarding your obligations and those of Safehire, including in relation to data protection, are set out within the Product Terms & Conditions and Data Processing Agreement

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