- Personal data is any information from which a living individual can be identified and sensitive personal data is personal data which reveals, or concerns: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data (e.g. genome sequencing data), biometric data (e.g. fingerprint or iris scanning data), health, sex life or sexual orientation.
- In compliance with the General Data Protection Regulation (Regulation 2016/679 of the European Parliament and of the Council), together with any accompanying legislation in any relevant member state and/or in the United Kingdom, along with any relevant supplementary national data protection regulations (together “Data Protection Requirements”), the Additives UK Privacy Notice (Recruitment) (“this Notice“) summarises the personal data and sensitive personal data that Additives UK collects and processes about you, the purposes of the processing and the rights that you have in connection with it.
- Additives UK processes certain personal and sensitive personal data relating to you and is the data controller in relation to that data.
- Who is covered by this policy?
- This policy relates to information that Additives UK may collect and keep on any individual who might apply for a position with Additives UK.
- Types of personal data collected
Additives UK may collect personal data during the recruitment process including but not limited to:
- Identification data, for example, your name, photograph, gender, date of birth;
- Contact details, for example, your home address, personal telephone numbers and email addresses;
- Employment and academic history, for example, your job title/position, grade, status, reporting line, place or places of work, salary, working hours, attendance, grievance or performance issues;
- Information on professional qualifications, achievements, skills, authorisations required in respect of your work, criminal records checking applications and responses and/or membership of a particular professional body;
- National or other identification documents, for example, your national ID/passport, “right to work” details, details of any visa applications and national insurance number;
The types of sensitive personal data (including data that could reveal your racial or ethnic origin, religious, political or philosophical beliefs, trade union membership, information about your health or sex life, genetic data or biometric data for the purposes of uniquely identifying a person) Additives UK may process includes, but is not limited to:
- health information, for example, [records of accidents at work, information relating to personal injury claims pursued,] medical certificates, fitness for work assessments or other occupational health reports and drug and alcohol test results;
- (on a voluntary basis) information about your racial/ethnic origin, gender and health conditions which may be required to comply with anti-discrimination laws and government reporting obligations, and which we may use to help ensure equal employment opportunities;
- information relating to criminal prosecutions as a part of criminal records checks and when you disclose the same; and
- other sensitive personal data you voluntarily provide in the course of the recruitment process.
- Sources of personal data
Usually you will have provided the personal and sensitive personal data Additives UK holds about you. In these circumstances it is vital that you help to ensure that this data is accurate and kept up to date.
There may be situations where such data is collected from other sources, for example:
- Information about any criminal proceedings, collected from criminal records checking bodies;
- Information about your financial standing and creditworthiness collected from credit reference checking organisations;
- Information about your previous employment (including your employment record) and other information about your suitability to work at Additives UK from any reference provided by you and/or from our third-party recruitment agency partners;
- Other information gathered from third party providers to carry out employment checks;
- Information about your health, including your fitness to carry out work and/or any accommodations or adjustments to be considered from your GP or another specialist medical or occupational health adviser; and
- Certain publicly available information from public sources (including the internet).
- Purposes and basis for processing personal data
Additives UK collects and uses your personal data primarily for the purpose of
- evaluating a potential employment relationship with you,
- taking steps to enter into a contract with you;
- complying with legal obligations such as checking your eligibility to work in a given country; and
- for the purposes of our legitimate interests, but only if these are not overridden by your interests, rights or freedoms.
Additives UK may also use your personal and sensitive personal data:
- where we consider it necessary to comply with laws and regulations, for example, collection and disclosure of personal data in compliance with regulatory requirements, and anti-discrimination (or other employment) laws;
- under judicial authorisation, or to exercise or defend the legal rights of Additives UK;
- where it is necessary to protect your vital interests (or those of another person) – for example, if you are incapacitated and there is a need to arrange for emergency medical treatment; and/or
- where it is necessary for the purpose of assessing of your working capacity or the diagnosis, treatment or care of a condition (for example, where Additives UK needs to instruct a medical professional to prepare a report on your fitness for work).
Where Additives UK is required by law to collect and process your personal data (for example, it is required to review, copy and check documents evidencing your right to work) or where such data must be collected and processed for entering a contract (for example, your account details, details of your salary etc. will be required to pay you) and you refuse to provide such personal data, Additives UK may be unable to employ you (or continue your employment).
- Who your personal data is shared with
Additives UK may make your personal data (including sensitive personal data) available to other legal entities within ITW’s corporate structure and across national boundaries, including to recipients in the United States (“US”).
Additives UK will also share personal data (including sensitive personal data) with third parties, including:
- those who provide products or services to Additives UK (such as financial, legal, occupational health and other advisers, providers of the HR platform, data storage and webmail / systems support, providers of checking services and payroll administrators);
- regulatory or other authorities;
- previous employers;
- governmental or quasi-governmental organisations;
- potential and actual purchasers of Additives UK; and/or
- other third parties where sharing is (1) pursuant to your consent or (2) as necessary (i) to comply with legal obligations, (ii) to establish, exercise or defend against actual or potential legal actions or (iii) to protect your (or someone else’s) vital interests
- Transfer of your personal data outside of Europe
Additives UK operates at a global level and therefore needs to transfer personal data to other countries where we operate, including the US.
Similarly, we might transfer your personal data to third parties based elsewhere.
When we export your personal information to a different country, we will take steps to ensure that such data exports comply with the Data Protection Requirements. For example:
- for transfers within the European Economic Area (EEA), we can be content that the same levels of protection will apply; and
- for transfers to other ITW entities in the US and/or to other third parties outside of the EEA, these are carried out pursuant to European Commission approved clauses.
- Data retention periods
We keep the personal information that we obtain about your during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.
We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination, after which they will be destroyed.
Additives UK seeks to ensure that your personal data is held and, where appropriate, securely deleted or destroyed in accordance with its Data Retention Policy.
- Your data protection rights
You have a number of data subject rights under the Data Protection Requirements, including the right to request:
- access to a copy of your personal data;
- erasure of your personal data (this is also referred to as the right to be forgotten);
- that processing of your personal data ceases (the right to object to processing);
- rectification of your personal data;
- restriction of processing of your personal data;
- portability of your personal data; and/or
- not to be subject to automated decision making.
You should note that there are a number of exceptions, exemptions, restrictions and qualifications in relation to the data subject rights described above. Additives UK will seek to engage with you to discuss any exceptions, exemptions, restrictions and qualifications after any request is made and if it considers that they apply in the circumstances.
If you have any questions about your data subject rights or wish to make a request to exercise them in relation to personal data referred to in this policy, you should contact the person referred to in section 10 below in writing.
- Questions and comments
If you have any questions or comments relating to this Notice, or to Additives UK’s privacy practices, you can address these to Jagir Bains, Financial Controller, Additives UK, 7 Westwood House, Westwood Way, Coventry, CV4 8HS. or by email firstname.lastname@example.org or phone 02476474069.
You have a right to lodge any complaints concerning data protection to the relevant local data protection authority (the Information Commissioner’s Office in the UK). However, we would of course encourage you to raise any issues internally first.