Privacy Notice Applicants

Grünenthal UK Privacy Notice - Applicants

Grünenthal Limited (Grünenthal UK) is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during recruitment activity, in accordance with relevant data protection legislation.

Grünenthal UK is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required by law to notify you of the information contained in this privacy notice.

This notice applies to individuals (referred to as “data subjects” in data protection legislation) who interact with Grünenthal UK as a result of any recruitment activity. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

1. Data protection principles

Data protection law says that the personal information we hold about you must be:

  • Processed lawfully, fairly and in a transparent manner.
  • Collected only for legitimate purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  •  Adequate for and relevant to the purposes we have told you about and limited only to what is necessary for those purposes.
  •  Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about
  • Processed in an appropriately secure manner.

2. The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are "special categories" of more sensitive personal data which require a higher level of protection.

We may collect, store, and use the categories of personal information about you set out in the table in Appendix A.

3. How is your personal information collected?

We typically collect personal information about potential candidates through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, personal connections, credit reference agencies or other background check agencies.

4. How we will use information about you

  • Where we need to in order to consider your CV or application and throughout your participation in any recruitment process with Grünenthal UK.
  • Where we need to comply with a legal obligation.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare

  • Where we need to protect your interests (or someone else's interests).
  • Where it is necessary in the public interest.

Situations in which we will use your personal information

We need all the categories of information listed in the table in Appendix A primarily to allow us to consider your CV or application and to enable your participation in any recruitment process with Grünenthal UK or to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are also listed in the table in Appendix A.

Some of the grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to continue with the recruitment process or we may be prevented from complying with our legal obligations (such as to ensure your health and safety).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so, which may involve us seeking your consent to such use of your personal information.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. How we use particularly sensitive personal information

Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

  • In limited circumstances, with your explicit written consent.
  • Where we need to carry out our legal obligations and in line with our data protection policy.
  • Where it is required in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme, and in line with our data protection policy.
  • Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where necessary in relation to legal claims or to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations

We may use your sensitive personal information:

  • about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work and to provide appropriate workplace adjustments.
  • about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law.

6. Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, to protect your interests (or someone else's interests) if you are not capable of giving your consent, or where you have already made the information public.

Where appropriate, we will collect information about criminal convictions as part of the recruitment process. We will use information about criminal convictions and offences to make a decision about your recruitment or appointment, so far as the law allows.

7. Automated decision-making

We do not envisage that any decisions will be taken about you using automated means.

8. Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information as you would receive for transfers within the EU.

Why might you share my personal information with third parties?

We may share your personal information with third parties where required by law or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

"Third parties" includes third-party service providers (including contractors and designated agents) and other companies within our group. The following third-party service providers may process personal information about you for the following purposes: Recruitment Agencies (it is not possible to specify which of these as it will vary depending on the particular recruitment exercise).

How secure is my information with third-party service providers and other companies in our group?

All our third-party service providers and other companies 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 in accordance with our instructions.

When might you share my personal information with other companies in the group?

We will share your personal information with other companies in our group as part of our recruitment-based reporting activities.

What about other third parties?

We may need to share your personal information with a regulator or to otherwise comply with the law.

9. Data security

We have put in place measures to protect the security of your information, whether it is held physically or virtually by Grünenthal UK. These measures include use of secured servers with limited access control to persons with appropriate clearance.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

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.

10. Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy, which can be provided on request from the HR Team. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. If you do not become an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy.

11. Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you during any recruitment process is accurate and up to date. Please let us know straight away if your personal information changes the recruitment process.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  •  Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to exercise any of the rights described above, please inform Grünenthal UK’s HR Director, UK, Ireland and Nordics in writing.

No fee usually required

You will not have to pay a fee to exercise any of the rights described above. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive or we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of the rights described above. This is an appropriate security measure to ensure that personal information is not disclosed to anyone who does not have the right to receive it.

12. Right to withdraw consent

There are limited circumstance where you may provide your consent to the collection, processing and transfer of your personal information for a specific purpose, however you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please inform the HR Director, UK, Ireland and Nordics. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

13. Data protection queries and complaints

If you have any questions about this privacy notice or how we handle your personal information, please contact the HR Director, UK, Ireland and Nordics. You have the right to raise a concern at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

14. Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice if we make any substantial updates whilst you are engaged in any recruitment process with us. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact the UK HR Director on ukhrtransactions@grunenthal.com.

Appendix A

Personal Information Legal Basis for Processing Reason for Processing
Candidate driven but likely to include: name, address, DOB, phone number, email address, nationality, NI number, photos, career history, referees’ details, education history, published articles Legitimate Interests (in appropriate resourcing for the business) Any special category data is simply stored and not further processed as it is not required for the recruitment process. Consent - information is provided by Applicants Job application - MyView recruitment systemn.
Name, career history, education history, published articles, current salary and benefits (and expectation) Legitimate Interests (in appropriate resourcing for the business) Consent - information is provided by Applicants Job Application - CVs from agencies with whom we have a relationship (speculative approaches are generally deleted)
Candidate driven but likely to include: name, address, DOB, phone number, email address, nationality, NI number, photos, career history, referees details, education history, published articles Legitimate Interests (in appropriate resourcing for the business) Consent - information is provided by Applicants Job Applications - Internal referrals
Name, date of application, contact details from all applicants with reference to specific vacancy Legitimate Interests (in keeping appropriate records of recruitment activity Job Applications - Recruitment Tracker
Name, email address, responses re key strengths Legitimate Interests (in ensuring the right candidate is hired for the role) Job Applications - Candidate strengths profile assessment
Depends on the information provided by the candidate, most contain at least the candidate's name, recruitment pack, interview notes Legitimate Interests (in retention of recruitment information in line with the data retention policy) Job Applications - Recruitment Packs

 

online:  02 Nov 2018