JOB APPLICANT- PRIVACY NOTICE
This privacy notice (“Privacy Notice”) applies to people applying for jobs (“you””your”) with the Hachette UK Group of Companies excluding Bookpoint Limited and Hachette UK Distribution Limited (see here) (“Hachette Companies” ”companies” “company” “we” “us “our”). Unless you are applying for a job at Hachette UK Distribution Limited or Bookpoint Limited your employer will be Hachette UK Limited. If you are applying for a job with Hachette UK Distribution Limited or Bookpoint Limited the successful candidate will be employed directly by whichever of those companies is specified as the place of work in the job advertisement.
The Privacy Notice, sets out the ways in which we collect, use and share the personal data (your Personal Information) of candidates who apply for jobs with us. It also explains what rights you have to access or change your Personal Information.
We are your Data Controller which means that we decide how your Personal Information is held, used and protected. We are required under data protection laws to notify you of the information set out in this Privacy Notice.
This Notice applies to Personal Information of job candidates and potential candidates for employment and any recruitment events or recruitment programs. It does not apply to any Personal Information of employees or independent contractors or authors or customers of the Company.
It applies to any Personal Information submitted in an application by post or in an on-line application such as an application tracking system or video interview system or via a third party recruitment agency.
Please read this notice and keep it together with any other privacy notice you may be provided with when we collect or process your Personal Information.
This Privacy Notice sets out your rights under data protection laws which are the Data Protection Act 2018 and any successor legislation and, from 25 May 2018, and as long as EU law remains in force in the UK, the EU General Data Protection Regulation 2016 (“GDPR”).
We take your privacy and our responsibility to protect your information seriously.
WHO WE ARE
Hachette UK Limited is a company registered in England under company number 2020173, with its registered address as set out below. We are part of the Hachette UK Group of companies
You can contact us as follows:
FAO: Legal Department (DPO)
Address: Carmelite House, 50 Victoria Embankment, London EC4Y 0DZ, UK
COMPLIANCE WITH DATA PROTECTION PRINCIPLES
We will comply with all applicable data protection laws.
Under the Data Protection Principles contained in the GDPR the Personal Information we hold about you must be:
- – used lawfully, fairly and in a transparent way
- – collected only for a valid purpose that has been clearly explained to you and not used in a way that is incompatible with these purposes
- – relevant to the purposes you have been informed about and limited to these purposes
- – accurate and kept up to date
- – kept only as long as necessary for the purposes you have been informed of
- – kept securely
WHAT INFORMATION WE COLLECT ABOUT YOU
Personal Information means any information about a living individual from which that individual can be identified. The information you provide to us might include:
- – your name, postal address, email address, phone number, (contact details);
- – date of birth;
- – marital status and dependents;
- – details of your educational history, qualifications, skills, experience and employment history;
- – test results of any tests you agree to take in relation to the application for a job with our company
- bank account details;
- – your current salary or remuneration and benefits, leaving date and reason for leaving (where provided by candidate);
- – your entitlement to work in the UK;
- – location of previous employment and workplace;
- – copy of passport and driving license;
- – recruitment information, CV, copies of any right to work in the UK documents, and cover letters, references or previous employers;
- – photographs;
- – video interviews.
Special Category Information
You may provide us with more sensitive information, known as Special Category (“Sensitive”) information which may include details about a person’s racial or ethnic origin, political opinions, religious, philosophical or similar beliefs, trade union membership, genetics, biometrics, health, sexual life or sexual orientation. If you supply this kind of information to us we will explain why we are collecting this and it will only be used where you have given your explicit consent or for lawful purposes which include relevant legal obligations and matters of substantial public interest as set out in this Privacy Notice. See the section on ‘How we use your information’ in relation to Sensitive information to find out more about our use of your Sensitive information.
HOW WE COLLECT INFORMATION
We collect your information during the recruitment process directly from you or from third parties.
Information we receive from third parties:
We collect information as appropriate to each applicant from third parties such as:
- – recruitment agencies, credit references agencies or other background check agencies, other company employees who have interviewed you;
- – medical practitioners with your consent;
- – referees;
- – previous employers.
Information about how you use our website and apps:
Our website may include links to third party websites, plug-ins and applications. By clicking on those links or enabling these connections you may allow third parties to collect or share data about you. We do not control these websites and are not responsible for their privacy notices. Please ensure that you read the privacy notices on any such external websites.
HOW WE USE INFORMATION ABOUT YOU
We use your information lawfully. We do not sell your information to third parties. However we may share your information as set out in the section ‘When we share your information’. The details of how we use your information and the legal bases for our use are set out below:
Where it is necessary to comply with legal obligations such as to check you are legally entitled to work in the UK
Where it is necessary for our ‘legitimate business interests’ (legitimate interests) or those of a third party and your interests and fundamental rights do not override those interests.
This means our legitimate interests in conducting and managing our business and our employment or working relationship with you.
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing you have rights and choices which include the right to object (please see the section headed ‘Your Rights and Choices’).
We may use your information for the purposes listed below on the basis of our legitimate interests:
- – to process any job applications you submit to us;
- – to work with our third party recruitment agency to process any job applications you submit to us;
- – to decide whether to recruit you;
- – to make decisions about your appointment;
- – to contact you in case of suitable vacancies;
- – to reimburse you any agreed expenses;
- – to enable us to comply with our policies and procedures and to carry out our legal obligations and enforce our legal rights, or to protect your rights, property or safety or those of our employees;
- – to detect and prevent fraud and unauthorised access or illegal activity;
- – to operate a safe and lawful business where we have a legal obligation;
We will use your Sensitive information in the following cases:
- – where necessary to carry out any employment law obligations in relation to your application;
- – where it is needed for the public interest such as for equal opportunities monitoring and reporting;
- – we will use your Personal Information relating to health to comply with your employment law rights to health and safety at work;
- – we will use your Personal Information relating to health in conjunction with our occupational health advisers to assess your fitness to work;
- – we may also process it where you have already made the information public;
- – where you have given your explicit consent for example in a survey;
- – where your Personal Information is required for legal claims.
If you do not provide Personal Information:
If you fail to provide certain Personal Information when requested we may not be able to process your application appropriately.
WHO CAN SEE YOUR INFORMATION
Your information may be processed by our staff or by the staff of third parties we work with to deliver our business. Processing can mean any activity that involves the use of information about someone that can identify them. All uses, for example, obtaining, recording, storing, disclosing, organising, retrieving, deleting and destroying are types of data processing. We take measures to ensure that third parties processing your information on our behalf are acting lawfully in accordance with our instructions and are subject to appropriate confidentiality requirements. We also have adequate technical and organisational safeguards in place in our company and with third party processors to protect your information. Third party processors of your information include:
- – our website hosts and operators, IT services and support providers (including applicant tracking and video interview app providers), database operators, site analytics providers and software developers;
- – our couriers and delivery services;
- – our auditors, technical consultants and legal advisors;
- – our fraud detection services.
WHEN WE SHARE YOUR INFORMATION
We may share your information within the Hachette Companies, in particular the company where the job vacancy is.
We may share your Personal Information with third parties:
- – recruitment agencies;
- – video interview app provider (for service improvement purposes);
- – any other third parties (including legal or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law or where we have a legal obligation to do so
Before we share your Personal Information we require third parties to enter into an agreement committing to compliance with all relevant data protection laws and we require them to have appropriate security measures in place to protect your information from unauthorised access, processing or use.
HOW WE LOOK AFTER YOUR INFORMATION
We look for opportunities to minimise the amount of Personal Information we hold about you. Where appropriate we anonymise and pseudonymise your information. It is held in electronic and paper form. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
- – ensuring the physical security of our offices, or other sites;
- – ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption;
- – maintaining a data protection policy for, and delivering data protection training to, our employees;
- – limiting access to your Personal Information to those in our company who need to use it in the course of their work.
HOW LONG WE KEEP YOUR INFORMATION
We will retain your information during the term of your interaction with us or for as long as we reasonably require the information for our legitimate interests or for the purposes of exercising our legal rights and obligations.
Save where information is provided via the online application tracking system as described in the section below or via our video interviewing system, we retain information relating to the applications of unsuccessful candidates in any recruitment for six months after the start date of the successful candidate. This includes application forms, letters, CVs, interview scoring sheets and any recruitment related correspondence. This is to enable providing references and to ensure that relevant information is available for any post-employment or post contract query relating to HMRC or Employment litigation.
If you are successful, your information will be kept along with any other employee related Personal Information you provide us in your personnel records for the duration of your employment with us and for seven years (7) after this date in accordance with our Privacy Notices.
Where you have provided your Personal Information via our online application tracking system, we will retain information stored on your candidate profile for 12 months, at which point we will send you an email reminder asking you to review your account, update your Personal Information and decide whether you want to keep your account active with us. Any candidates with idle accounts that have not opted to keep their account open will have their data anonymised. This unidentifiable data will be used for reporting and auditing purposes by the HR team.
Where you have participated in a video interview with us, candidates’ information is retained for 12 months when it is automatically deleted. Anonymised versions of interviews may be retained longer by the interview app provider for their service improvement purposes. The app provider is the Data Controller of any Personal Information retained in this way as set out in their Privacy Notice.
INTERNATIONAL TRANSFERS OF YOUR INFORMATION
Whenever we transfer your Personal Information out of the European Economic Area (EEA) we will take all steps necessary to ensure that it is adequately protected and processed in accordance with this Privacy Notice by using all appropriate cross-border transfer safeguards where there is not an adequacy decision from the EU Commission in place, such as:
- – by entering into the European Commission’s Standard Contractual Clauses with the recipient which give personal data the same protection it has in the EEA; and
- – where the recipient is in the US, the EU-US Privacy Shield if the recipient is part of the EU-US Privacy Shield Framework.
Please contact Human Resources if you would like additional information on the specific means used by us when transferring your personal data outside of the EEA.
AUTOMATED DECISION MAKING
Automated Decision Making occurs when Personal Information is used by an electronic system to make a decision without human intervention for example where a computer reviews applications.
You will not be subject to automated decisions which have a significant impact on you based solely on automated means unless we have a lawful basis for doing so and have notified you.
We do not envisage making any decisions about you by automated means but we will notify you in writing if this position changes.
KEEPING THE INFORMATION UP TO DATE AND ACCURATE
Please keep us informed if your Personal Information changes during your application. This is important so we can ensure that the information we hold about you is correct and up to date.
YOUR RIGHTS AND CHOICES
You have choices and rights in respect of the information that we hold about you, including:
Your right to request access to the information that we hold about you (“data subject access request or DSAR) This is the right to receive a copy of any information we hold about you in a structured, commonly-used, machine readable format or in another format of your choice;
You will not have to pay a fee to obtain access to your information unless your request is clearly unfounded or excessive. In such case a reasonable fee may be charged. We may require you to provide us with information to help confirm your identity and ensure your right to access the information. This is to make sure that the personal data is disclosed to a person lawfully.
Your right to ask us, in certain circumstances, to delete information we hold about you;
Your right to ask us to correct information we hold about you if it is inaccurate or incomplete;
Your right to ask us, in certain circumstances to restrict processing of your information;
Your right to request that we transfer your information to another service provider in a structured, commonly used, machine-readable format;
Your right to Object
You have the right to object to our using your information on the basis of our legitimate interests (refer to section ‘How we use your information’ above to see when we are relying on our legitimate interests). If you want to do this you can contact us using the details in the section ‘Who we are’.
Your right to withdraw Consent
The right to withdraw your consent for our use of your information in reliance on your consent (refer to section ‘How we use your information’ to see when we are relying on your consent), which you can do by contacting us using any of the details in the section ‘Who we are’.
You have the right to receive a copy of any information we hold about you in a structured, commonly-used, machine readable format or in another format of your choice;
All the above rights may be exercised by contacting us at contacting us at email@example.com or by sending us a written request by post to Carmelite House 50 Victoria Embankment, London EC4Y 0DZ, UK for the attention of the Legal Department
Your right to Complain
Please contact us if you have any questions or are unhappy about the way your information is used. We hope we will be able to resolve any problems or issues you may.
You also have the right to lodge a complaint about us and our use of your information to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence.
CHANGES TO THIS PRIVACY NOTICE
We may make changes to this Privacy Notice from time to time. We will post any changes to the Hachette UK website (www.hachette.co.uk).
This Privacy Notice was issued on 26 June 2019.