What is the purpose of this document?
Mark Warner Ltd (“Mark Warner”, “we”, “our” and “us”) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). This notice describes how and why your personal data will be used, namely for recruitment purposes, and how long it will usually be retained for. It provides you with certain information that must be provided under the applicable laws.
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter.
- The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, national insurance number, and passport number.
- Any information you provide to us during an interview.
- CCTV footage.
We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about candidates from the following sources:
- You, the candidate.
- CCTV footage.
- Recruitment agency, from which we collect the following categories of data: CV, proof of address, contact details, qualifications, references, EHIC, National insurance number and DBS (for certain positions). The agencies we use are; Kings Recruit, Seasons to Seasons, Helen Lasik, Silver Swan, Chef Foundation.
- Disclosure and Barring Service in respect of criminal convictions.
How we will use information about you
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role.
- Carry out background and reference checks, where applicable, in order to assess your suitability for the role.
- Communicate with you about the recruitment process.
- Enter into an employment or other contractual relationship with you, if applicable.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
- Maintain our building security.
It is in our legitimate interests to decide whether to appoint you to work for us since it would be beneficial to our business to appoint someone to that role. We will ensure you fundamental rights are not overridden.
Having received your CV and covering letter [we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references and carry out a criminal record check, if applicable before confirming your appointment. If you choose to accept an appointment we need to process your personal information in order to take steps to enter into the employment or other contractual relationship with you.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use particularly sensitive personal information
We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during interview.
Information about criminal convictions
We envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular, the role of childcare and waterfront roles and land sports requires a high degree of trust and integrity since it involves dealing with children and so are required to obtain enhanced disclosure of your criminal records history in order to safeguard children and comply with our legal obligations.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application: All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will retain your personal information for a period of 6 months after we have communicated to you our decision about whether to appoint you to the role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
Rights of access, correction, erasure, and restriction
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- A data subject access request.
- Request correction of the personal information that we hold about you.
- Request erasure of your personal information in certain specified situations.
- Object to processing of your personal information in certain specified situations.
- Request the restriction of processing of your personal information.
- Data portability, in certain circumstances.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact firstname.lastname@example.org in writing.
Complaint to the ICO
If you are unhappy with the way in which we have used your personal information, you have the right to lodge a complaint with the Information Commissioner’s Office, which is the data protection authority where Mark Warner is located.
Chief Compliance Officer
We have appointed a Chief Compliance Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the data privacy manager. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.