EU Recruitment Privacy Notice
Scope of privacy notice
The notice focuses on individuals who are applying to work for us in the European Union and the United Kingdom and the data we process as part of that process. We have a separate Workplace Privacy Notice that applies to our current and former employees for these jurisdictions.
This Recruitment Privacy Notice comprises this document (the Core Notice) and the Supplementary Information in the Annex to this document.
The Supplementary Information section contains a Glossary, in which we explain what we mean by “personal data”, “processing”, “special personal data” and other terms used in this Recruitment Privacy Notice.
Personal data – what we hold and why we process it
We process this data for the purposes of our business, including management, administrative, employment and legal purposes. The Supplementary Information provides more specific information on these purposes.
See Further information on the data we process and our purposes.
Legal grounds for processing personal data
Where the personal data comes from and who gets to see it
Other personal data may come from third parties such as recruiters acting on your behalf or from your references.
Your personal data will be seen internally by managers, HR and, in some circumstances (if you join us) colleagues. We will where necessary and as set out in this Recruitment Privacy Notice also pass your data outside the organisation, for example to people you are dealing with and background checking agencies.
Further information on this is provided in the Supplementary Information. See Where the personal data comes from and Who gets to see your personal data?
How long do we keep your personal data?
See Retaining your personal data – more information in the Supplementary Information.
Transfers of personal data outside the EEA
Further information on these transfers and the measures taken to safeguard your personal data are set out in the Supplementary Information under Transfers of personal data outside the EEA – more information.
Your personal data rights
90-100 Southwalk Street
Attention: Data Privacy
Status of this notice
Annex To Core Notice
Personal data “processed automatically” includes information held on, or relating to use of, a computer, laptop, mobile phone or similar device. It covers data derived from equipment such as access passes within a building, data on use of vehicles and sound and image data such as CCTV or photographs.
“Processing” means doing anything with the data. For example, it includes collecting it, holding it, disclosing it and deleting it.
“Special personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data. These types of data are subject to special protection under the law.
References in the Recruitment Privacy Notice to “employment”, “work” and similar expressions include any arrangement under which an individual works for us or provides services to us, or applies to provide services. This includes individuals who are our employees and also those who provide services under a freelance or independent contractor arrangement. Similarly, when we mention an “employment contract”, this should be taken to include any contract with an employee, a freelancer or a contractor; and when we refer to ending your potential “employment”, that includes terminating a freelance engagement or a contract for services.
We use the word “you” to refer to anyone within the scope of this Recruitment Privacy Notice.
Legal grounds for processing personal data
What are the grounds for processing?
|Term||Ground for processing||Explanation|
|Contract||Processing necessary for performance of a contract with you or to take steps at your request to enter a contract||This covers carrying out our contractual duties and exercising our contractual rights.|
|Legal obligation||Processing necessary to comply with our legal obligations||Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination.|
|Legitimate Interests||Processing necessary for our or a third party’s legitimate interests||We (and third parties) have legitimate interests in carrying on, managing and administering our respective businesses. Part of managing businesses will involve the processing of your personal data. Your data will not be processed if, in processing your data, your interests, rights and freedoms related to the data override the businesses’ interests in processing the data for businesses purposes.|
|Consent||You have given specific consent to processing your data||In general processing of your data in connection with employment is not conditional on your consent. But there may be occasions where we do specific things such as provide a reference and rely on your consent to do so.|
Processing special personal data
Further information on the personal data we process and our purposes
The examples in the table cannot, of course, be exhaustive. For example, although the table does not mention personal data relating to criminal offences, if we were to find out that someone applying to work for us was suspected of committing a criminal offence, we might process that information if relevant for our purposes.
|Purpose||Examples of personal data that may be processed||Grounds for processing|
|Recruitment||Standard data related to your identity (e.g. your name, address, email address, ID information and documents, telephone numbers, place of birth, nationality, contact details, professional experience and education (including university degrees, academic records, professional licenses, memberships and certifications, awards and achievements, and current and previous employment details), financial information (including current salary information) language skills, and any other personal data that you present us with as part of your application related to the fulfilment of the role.
Information concerning your application and our assessment of it, your references, any checks we may make to verify information provided or background checks and any information connected with your right to work.
If necessary, we will also process information concerning your health, any disability and in connection with any adjustments to working arrangements.
Please note also that we may process your personal data in relation to an application for one job, in relation to an application for another job for which we feel you may be suitable.
|Administering our recruitment process||Evaluating your experience and qualifications against the requirements of the position you are applying for.
Administering our online careers portal.
Communicating with you in respect of any offer of employment we choose to make and providing you with information about our onboarding process.
|Entering into a contract with you (if you are made an offer by us)||Information on your terms of employment from time to time including your hours and working patterns, your pay and benefits, such as your participation in pension arrangements, life and medical insurance; and any bonus or share schemes.||Contract
|Contacting you or others on your behalf||For the purpose of gathering references.||Contract
|Financial planning and budgeting||Information such as your proposed salary and (if applicable) envisaged bonus levels.||Legitimate interests|
|Physical and system security||CCTV images upon attendance for interview at our premises.
|Providing information to third parties in connection with transactions that we contemplate or carry out||Information on any offer made to you and your proposed contract and other employment data that may be required by a party to a transaction such as a prospective purchaser, seller or outsourcer.||Legitimate interests|
|Monitoring of diversity and equal opportunities||Information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age as part of diversity monitoring initiatives. Such data will aggregated and used for equality of opportunity monitoring purposes. Please note we may share aggregated and anonymized diversity statistics with regulators if formally required / requested.||Legitimate interests|
|Disputes and legal proceedings||Any information relevant or potentially relevant to a dispute or legal proceeding affecting us.||Legitimate interests
Please note that if you accept an offer from us the business will process further information as part of the employment relationship. We will provide you with our full Workplace Privacy Notice as part of the on-boarding process.
Where the personal data comes from
Please note we may also receive data from third party recruiters, agents and similar organisations as a part of the recruitment process.
Who gets to see your personal data?
We may disclose your personal data if it is necessary for our legitimate interests as an organisation or the interests of a third party, such as if we use a recruitment portal managed by a third party provider we may send your personal data on to that third party (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy).
We may also disclose your personal data outside the group:
Retaining your personal data – more information
If your data is only useful for a short period (for example, CCTV footage data) we will delete it.
Personal data relating to job applicants (other than the person who is successful) will be deleted in compliance with applicable law.
Transfers of personal data outside the EEA – more information
Access to your personal data and other rights
You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including:
If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted. If you have provided us with data about yourself (for example your address or bank details), and the ground for processing is Consent or Contract, you have the right to be given the data in machine readable format for transmitting to another data controller.
If we have relied on consent as a ground for processing, you may withdraw consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.