Applicant Privacy Notice
Issued: 14th May 2018, updated August 2018
We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. It is important that you read all of this Notice carefully as it sets out how Altro Limited ("the Company", "we" or "us") handles your personal information when you apply for a job or other role with us and the rights you have in connection with that information. The term "applicants" is used in this Notice to refer to anyone who applies for a job role, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis). This includes applicants to each of our brands: Altro and Autoglym.
If you are in any doubt, or have any comments or questions about this Notice, please contact us using the contact details set out at Section 8 below.
2. Types of personal information we collect when you apply
Information that we collect automatically
You can visit the recruitment section of our websites (Altro: http://careers.altro.co.uk/ / Autoglym: https:// http://careers.autoglym.co.uk/) ("Websites") and search for jobs without providing personal information. However, we do collect certain information automatically from your device when you visit our Websites. For further information, please see the privacy notice that applies to the use of our Websites.
Personal Information collected from you
The types of personal information we collect and process when you apply for a role with the Company includes (but is not limited to):
- Identification data and contact details – including your name, address, email address, phone number and other contact information, gender, date of birth, nationality/ies, national identifiers (such as national ID/passport, social security number(s)) and your current employer and car registration (where provided as part of our reception sign-in process).
- Employment history – such as previous employers and job titles/positions and your reason for leaving.
- Background information – such as academic/professional qualifications, job qualifications, education, details included in your application form / CV (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) and details of references provided by them (references will usually only be contacted after we make an offer of employment).
- Details of your immigration/visa status and right to work.
- 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).
- Information gained through psychometric testing, including ability testing, a personality profile (where this is carried out as part of the recruitment process) and (for senior appointments) a report prepared by a business psychologist.
- Certain role-specific information, including details of points, endorsements or bans for applicants to a role which involves driving on Company business.
- Other information you voluntarily provide throughout the process, including through assessment centres / exercises and interviews.
As a general rule, during the recruitment process, we try not to collect or process any of the following: information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health/sex life ("Sensitive Personal Information"), unless authorised by, or where necessary to comply with, applicable laws.
However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Sensitive Personal Information for legitimate recruitment-related purposes, for example:
- obligations (any reports produced by us in this context would not directly identify you);
- information about your physical or mental condition to consider accommodations for the recruitment process and/or subsequent job role; or
- Sensitive Personal Information which you choose to share with us during the recruitment process.
Personal information collected from other sources
We may collect some personal information (or in some circumstances Sensitive Personal Information) from other sources. For example:
- References provided by referees.
- Other background information provided or confirmed by academic institutions, training or certification providers, customers who assist in the recruitment process (where applicable) and providers of background checking services.
- Information on any endorsements, bans or other driving-related offences through the providers of driving licence checks (for those applicants whose role would involve driving on Company business).
- Information provided by recruitment or executive search agencies.
- Information collected from publically available sources, including any social media platforms you use or other information available online.
(in each case, where permissible and in accordance with applicable law).
3. Purposes for processing personal information
We collect and use this personal information primarily for recruitment and resource planning purposes, and to comply with applicable laws and regulations. That includes using it to identify new talent, to match candidates to job vacancies, to conduct screening / verification, to determine your qualifications and suitability for a position, to administer assessments and interviews, to reach a hiring decision, to make offers and provide contracts of employment (and to otherwise communicate with you about the recruitment process) and to conduct pre-employment checks including determining your right to work.
If you are accepted for a role at the Company, the information collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with our Employee Privacy Notice.
If you are not successful, we may ask you if you would like to opt in to our talent pool, which would involve us (through our recruitment portal providers) retaining your application data to allow us to consider and, if appropriate, contact you for other suitable openings within the Company. If you do not agree to this, we will delete your personal information six months after the end of the recruitment process. If you do agree, we will retain your personal information for 6 months after communicating our decision and will contact you again at the end of that process to ask whether you wish to remain in the talent pool or not. You can also request that we delete your application by contacting us using the contact details provided in Section 8 below.
4. Who we share your personal information with and transfers abroad
We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of the information is maintained.
Transfers to third parties
We may make certain personal information available to third parties (including those who provide services relating to the recruitment process to us). For example, some information will be made available to:
- 360 Resourcing, who provide our recruitment portal;
- providers of psychometric and ability testing e.g. Psycruit, who host psychometric testing tools where this is incorporated within the recruitment process and Eillis Borne Consulting, who assist with more detailed numerical and verbal reasoning and produce reports in relation to applicants for senior appointments;
- recruitment or executive search agencies involved in your recruitment, e.g. Hays, Fresh Recruit, Lawrence Dean, Abacus Consulting, Vitae, Investigo, Jenrick, CK Science, Catch, Computer People, Marcus Knightley, Cavendish Maine, Inside Out, MPloy, P+S Personnel, Brand, ISupply, DMJ, George Thomas Recruitment, Manesis Search and Selection, BMS, Sterling Sales & Integra;
- information on your visit to our premises and, if relevant, your current employer and car registration number, collected and stored through Zap-In, the providers of our reception sign-in service;
- customers who may be involved in our recruitment process. Information shared with customers during recruitment will be limited to your CV, application form and certain other background information;
- data storage, shared services and recruitment platform providers, IT developers and support providers, e.g. Microsoft, Reed, CV Library, Total Jobs, Indeed.
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 court order, 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.
Transferring information abroad
In some cases, the sharing described above may result in your personal information being transferred internationally, including from the European Economic Area to a country outside it. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
In particular, the Company has entered into arrangements with third party service providers that process your personal information in non-EEA countries around the world, including via sub-processors. When we export personal information from the European Economic Area ("EEA") to a country outside it, such as the United States, we will rely on decisions of the European Commission that the relevant territory upholds an adequate level of data protection, or implement measures to provide an adequate level of data protection under EU law.
The measures we take include:
- implementing the European Commission’s Standard Contractual Clauses (under Article 46.2 of the General Data Protection Regulation) for such transfers.
- relying on the fact that a US-based recipient of the personal information has self-certified to the EU-US Privacy Shield (pursuant to Article 45 of the General Data Protection Regulation).
Our Standard Contractual Clauses, and the other mechanisms we rely on can be provided on request.
5. Legal basis for processing personal information
Under European data protection law, our legal basis for processing your personal information as part of the recruitment process is:
- our legitimate interests (which are summarised above in Section 3 and 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);
- 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;
- (in limited circumstances) where we have your consent to do so. Where we have requested your consent to process your personal data, 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.
Where we request personal information and Sensitive Personal Information from you, you can choose not to provide it to us. However, unless otherwise indicated, the information we request from you is required in order to enter into our contract of employment with you or in order to comply with our legal obligations. Failure to provide it prevents us from effectively commencing our contractual relationship with you or completing our recruitment process and/or complying with those legal obligations, which may mean we are unable to continue with the recruitment process in relation to you.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided in Section 8 below.
6. Data retention periods
Personal and Sensitive Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally this means your personal information will be retained:
- in accordance with the retention periods set out in the Company's Employee Privacy Notice (where we engage you to carry out work); or
- for six months after the end of the recruitment process, unless you agree to us retaining your information in the talent pool (see Section 3 above) in which case we will contact you every 6 months to check whether or not if you wish to remain on that talent pool. If/when you communicate that you do not wish to remain, we will delete your data.
More detailed information is available in the Company's Data Retention Policy.
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. Your local data protection authority is the Information Commissioner's Office (the ICO), and you can contact the ICO via email (firstname.lastname@example.org) or phone (0303 123 1113).
Of course, we would prefer you to raise any concerns with the Company directly first (on the contact details set out in Section 8 below).
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
8. Contact details