Recruitment Privacy Notice
Introduction
Bakkavor is committed to protecting the privacy and security of your personal information. This notice explains what personal data (information) we hold about you, how we collect it, and how we use and share information about you during your recruitment process. We are required to notify you of this information under data protection legislation. Please ensure that you read this privacy notice and any other similar notice we may provide to you from time to time when we collect or process personal information about you. We may update this notice at any time.
Who collects the information?
Bakkavor Foods Limited (the ‘Company’) collects and processes certain information about you as part of the recruitment process and is the ‘data controller’.
This information is also used by our affiliated entities and group companies, including Bakkavor Group plc (our ‘Group Companies’), and so, in this notice, references to ‘we’ or ‘us’ mean Bakkavor and our Group Companies.
Data protection principles
We will comply with the data protection principles when gathering and using personal information. This means data will be (i) used in a lawful, fair and transparent way; (ii) collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes; (iii) adequate, relevant and limited to what is necessary for those purposes; (iv) accurate and kept up to date; (v) kept only as long as necessary for the purposes we have told you about; and (vi) kept securely.
About the information we collect and hold
Types of Information
We may collect, store, and use the following information during the recruitment process:
- Your name, title, sex, gender and contact details (i.e. address, home and mobile phone numbers, email address).
- Details of your academic and/or professional qualifications*, experience, employment history (including job titles, salary and working hours) and interests.
- Details of your referees.
- Information obtained about you from your referees, including your previous academic and employment history, details of any conduct, grievance or performance issues, appraisals and time and attendance records*.
- Any information you provide to us during an interview.
- Any other information you provide to us in your curriculum vitae, covering letter or application form
We may also collect, store and use the following types of more sensitive information:
- Your racial or ethnic origin, in order to comply with equal opportunities legislation.
- Information about your health, including any medical condition, health and sickness records.
- Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information*.
- Information regarding any criminal record/unspent convictions.
- A copy of your driving licence.
You are required (by law or in order to enter into your contract of employment) to provide the categories of information marked ‘*’ above to us to enable us to verify your right to work and suitability for the position. A copy of your driving licence may be required for certain positions.
How we collect the information
We may collect this information from you, your referees (details of whom you will have provided), your education provider, the relevant professional body, the Disclosure and Barring Service in respect of criminal convictions, and the Home Office.
Why we collect the information and how we use it
We will typically collect, store and use this information for the following purposes:
- To assess your skills, qualifications, and suitability for the work or role.
- To carry out background and reference checks, where applicable.
- To communicate with you about the recruitment process.
- To communicate with you in the future about vacancies which may arise from time to time which we consider you would be interested in and are suited to.
- To keep records related to our hiring processes.
- To take steps to enter into a contract, where applicable.
- To comply with legal or regulatory obligations (e.g. our obligation to check that you are eligible to work in the United Kingdom).
- For the performance of a task carried out in the public interest.
- For the purposes of our legitimate interests, but only if these are not overridden by your interests, rights or freedoms.
Automated Screening
As part of your recruitment process, Bakkavor may utilise computer software to automate the evaluation of initial screening questions. The purpose of screening questions is to verify your eligibility for the role you are applying for, for example by checking that you have the right to work in the United Kingdom.
Automating screening enables Bakkavor to streamline its recruitment processes and improve the candidate experience. However, you have certain rights in respect of automated screening which you are entitled to exercise at any time. These rights include the ability to:
- obtain intervention from a human Talent Acquisition Agent;
- express your views on the process; and/or
- contest the outcome of the process.
If you wish to exercise any of these rights, please contact our Talent Acquisition Team who will be happy to assist. Our Talent Acquisition Team is available on 0345 266 1843 (option 1) between the hours of 8:00am and 6:00pm, Monday to Friday excluding bank holidays.
Sensitive Data
Some of your particularly sensitive personal data will fall within ‘special categories’ (for example, information related to your racial or ethnic origin). We will not use this information to make recruitment decisions but 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 or exercise rights in relation to your employment with us and in line with our Data Protection Policy.
- Where it is needed 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.
- Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed 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.
Please note that some of these grounds may overlap and there may be several grounds which justify our use of your personal information.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
Criminal Convictions
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect this information as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences to consider if the conviction puts other members of staff and the public at risk or to evaluate suitability for certain job types e.g. finance staff.
We are required to process information about criminal convictions in this way to carry out our obligations as an employer.
Sharing Information
We may make information available (for the purposes described above) to our Group Companies. This may occasionally include Group Companies outside of the European Economic Area (EEA), in particular the US, China & Hong Kong.
We sometimes use third parties to process data on our behalf for the purposes described above. Such processing may be undertaken outside of the UK and the EEA, including countries that do not have local data protection laws equivalent to those in the UK and the EEA.
We may also need to share some of the above categories of personal information with other third parties, such as external contractors, professional advisers and potential purchasers of some or all of our business or on a re-structuring of the business. Where possible this information will be anonymised.
All our third-party providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow third party providers to use your data for their own purposes and they will process your information only in accordance with our instructions.
How long we keep your information
We keep the personal information that we obtain about you during the recruitment process for the following periods:
- For candidates who have created a Bakkavor Careers account profile, we will retain your data for two years from creation of your Bakkavor Careers account profile, or from the date of your last account profile login, whichever is later.
- For candidates applying via Anna (virtual recruiting assistant), we will retain your data for two years from the date your application is made.
If your application is successful and you become employed by us, we will keep some of your personal information beyond these periods as set out below.
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 (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised.
If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment. For further information, see our Privacy Notice – Employees, Workers, Apprentices and Contractors
Talent Pool
We maintain a 'Talent Pool’ of candidates who we believe may have the skills and experience to work for us in the future. If you are added to the Talent Pool, we may contact you regarding roles which we consider you to be suited to. Please email dataprotection@bakkavor.com if you do not wish to be added to the Talent Pool, or have been added and would like to be removed.
Your rights to your information
It is important that the personal information we hold about you is accurate and current.
You have a duty to inform us if there are any changes to your personal information.
You also have other rights regarding your personal data which include your rights to:
- Make a ‘Data Subject Access Request’ – you may request access to your personal information and to check it is being lawfully processed.
- Request correction of the personal information that we hold for you.
- Request erasure of your personal information where there is no good reason for us continuing to process it.
- Object to processing – you may object 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.
- Request the restriction of processing of your information (e.g. whilst we check its accuracy).
- Request the transfer of your personal information to another party.
In addition, in the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. 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.
Should you wish to invoke any of the above rights or withdraw consent, please contact your local recruitment representative or email dataprotection@bakkavor.com for further information. Please note a fee will not be required for any data information requests unless they are clearly unfounded or excessive. We will require specific information to help us confirm your identity to ensure that the person requesting the information has a right to it.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
Where your information is shared with third parties, we carry out due diligence to ensure that your information will be processed in a secure manner and treated in accordance with the law.
Where your data is transferred outside the UK and the EEA, we will carry out due diligence checks to ensure the data is stored securely and in accordance with the law.
Further Information
If you have any questions or concerns regarding this Privacy Notice or how we handle your personal information please contact your local recruitment representative or email dataprotection@bakkavor.com.
You have the right to contact the UK Supervisory Authority, the Information Commissioner’s Office (‘ICO’) at ico.org.uk/concerns/ or 0303 123 1113 for further data protection information and advice, or to lodge a complaint.
Data Privacy Notice (Recruitment) – Version 6, October 2024
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