Recruitment Privacy Notice
Last Updated: May 2020
1. Introduction
2. Types of personal information we collect when you apply
- Identification data and contact details - including your name, address, email address, phone number (home and mobile) and other contact information, nationality/ies, driving licence and a photograph.
- Employment history such as previous employers, job titles/positions and geographic location.
- Background information such as academic/professional qualifications, degrees, skills, language proficiency, job qualifications, education, details included in your CV/résumé (which might include details of any memberships or interests constituting sensitive personal information), transcripts and employment references.
- Details of your nominated referees (including their name, contact details, employer and job role).
- Details of your immigration/visa status
- Previous applications/roles (information relating to previous applications you have made to the Company's Group and/or any previous employment history with the Company's Group).
- Other information you voluntarily provide throughout the process, including through assessment centres / exercises and interviews.
- References provided by referees.
- Other background information provided or confirmed by academic institutions and training or certification providers.
- Information provided by recruitment or executive search agencies.
- Information collected from publicly available sources, including any social media platforms (such as LinkedIn) you use or other information available online.
- Details of your immigration/visa status
3. Purposes for processing personal information
4. Who we share your personal information with and transfers abroad
We may make certain personal information available to third parties who provide services relating to the recruitment process to us, including:
- recruitment or executive search agencies involved in your recruitment;
- data storage, shared services and recruitment platform providers, IT developers and support providers and providers of hosting services in relation to our careers website, e.g. , Greenhouse (recruiting software and job applicant information), Google (cloud storage provider and email system);
- third parties who provide support and advice including in relation to legal, financial / audit, health and safety, security and intel and whistleblowing / reporting issues.
We may also disclose personal information to third parties on other lawful grounds, including:
- Where you have provided your consent;
- To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant;
- In response to lawful requests by public authorities (including for tax, immigration, health and safety, national security or law enforcement purposes);
- As necessary to establish, exercise or defend against potential, threatened or actual legal claims;
- Where necessary to protect your vital interests or those of another person; and/or
- In connection with the sale, assignment or other transfer of all or part of our business.
5. Legal basis for processing personal information
We may also disclose personal information to third parties on other lawful grounds, including:
- our legitimate interests (as summarized above in Section 3) (which are not overridden by your data protection interests or fundamental rights and freedoms, particularly taking into consideration the safeguards that we put in place, for example, those outlined in Section 4 above);
- to comply with applicable immigration and/or employment laws and regulations;
- to take steps prior to entering an employment contract with you, where you are considered for employment;
- in circumstances where you have made the data public;
- where we have your consent to do so. Where we have requested your consent to process your personal information, you have the right to withdraw your consent at any time;
- to protect the rights and interests of the Company's Group, our employees, applicants and others, as required and permitted by applicable law.
6. Data retention periods
We may also disclose personal information to third parties on other lawful grounds, including:
- in accordance with the retention periods set out in the Company's Data Retention Notice (where you become our employee); or
- for a period of 24 months after confirmation that your application was unsuccessful unless you request that we delete your application.
7. Your data privacy rights
You may exercise the rights available to you under applicable data protection laws as follows::
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below.
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. - You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries are available here.)