Pentland Chaussures Limited – Recruitment Privacy Notice
The purpose of this Notice is to explain how we handle personal data about our job applicants and to explain the rights that they have under data protection law. In this Notice, we refer to this type of information as “Recruitment Data”.
This Notice applies to applications submitted via our careers website and third parties, such as recruitment agencies and job boards. It also applies to applications submitted via other means, such as by post and email.
Pentland Chaussures Limited (or “PCL”) means Pentland Chaussures Limited and any of its subsidiaries and affiliates, as existing from time to time. PCL is also referred to in this Notice as “we”, “us” or “our”.
1. WHAT RECRUITMENT DATA DO WE COLLECT?
We will generally only collect Recruitment Data in the recruitment process that is necessary to assess you for the position for which you have applied. This may include the following categories of data:
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Application information: This information will generally tell us who you are and help build a picture of your capabilities and suitability for certain positions. This type of information may include your name, contact information, current company, information contained in your CV/resume (e.g. professional qualifications, previous employment history, place of residence, current base compensation, additional bonuses and/or commission and personal interests and experiences), information contained in your social media accounts or personal websites or accounts (e.g. LinkedIn or Twitter), information about the type of work and projects you have been involved with and any other information you may wish to provide to us as part of your application.
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Recruitment process information: This is information collected as a result of the recruitment process, such as your performance at assessment centres or interview and information provided by your referees.
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Future opportunities information: This is information collected in order to keep in touch with you about future job opportunities at PCL, such as your name, email, LinkedIn profile, location, field of expertise and the kind of role you are interested in.
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Careers website information: This is information related to your use of our careers website, for example your IP address. This information may be collected using cookies and similar technology.
Personal data relating to medical information will only be sought where permitted by applicable law.
Criminal record checks are carried out on applicants for Executive and Finance roles at PCL and will consist of Basic Disclosure and Barring Service (“DBS”) checks which will be carried out via a third party at the final stage of onboarding once you have accepted an employment offer and signed an employment contract.
We generally receive Recruitment Data either (a) directly from you (for instance when you provide information as part of your application or during the recruitment process) or (b) from third parties (for instance from recruitment agencies). We will indicate where the information we have requested is mandatory or optional. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some circumstances this may mean we are unable to process your application.
2. WHAT WILL WE DO WITH YOUR RECRUITMENT DATA?
The main purposes for which we use your Recruitment Data include:
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Supporting and Processing your Application, for example, so we can assess your ability to meet the job specification, in order to shortlist applicants and to verify references and professional qualifications provided by applicants.
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Improving our Application Process, for example to ensure that our careers website is user-friendly and contains appropriate and helpful information.
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Security Management, for example to ensure the security of our premises, assets, information, employees and other personnel.
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Legal and Regulatory Compliance, for example to ensure compliance with health & safety requirements and other legal or fiscal obligations, or in connection with litigation or an internal investigation or audit and to ensure compliance with our policies regarding anti-money laundering, bribery and corruption, as well as equal opportunities monitoring.
We may verify the Recruitment Data you provide during the recruitment process and/or collect personal data about you from third party sources to assist with our “Pre-Employment Checks”. If this occurs:
- You will be told in advance which aspects of your Recruitment Data will be verified including an explanation of how the Pre-Employment Checks will be carried out; and
- Information about criminal convictions (if collected) or medical information will only be collected through official authorised sources and in accordance with applicable law.
The results of any DBS check will be sent to you, and you have no obligation to disclose the results us and we do not receive details of any criminal offences.
Where it is necessary and appropriate for the role you have applied for, we may also require you to undertake drug and alcohol testing prior to commencing your employment with us.
We will only process your Recruitment Data where we have a legal basis for doing so. Generally, we will be processing it to help us to decide whether to enter into a contract of employment with you. At other times, we will be processing your Recruitment Data because you have consented to us doing so. In which case you can withdraw such consent at any point.
We may also process your Recruitment Data to comply with our legal obligations or because it is in our legitimate business interests to do so (for example, where it is necessary to understand our applicants in sufficient detail so we can operate an effective recruitment process).
3. WHO IS YOUR RECRUITMENT DATA DISCLOSED TO?
(a) Within PCL
We restrict access to Recruitment Data to people within our group of companies who have a “need to know” such information. For example, certain individuals within PCL will have access to your Recruitment Data in order to process your application and manage the recruitment process (this may include individuals in our HR team and individuals to whom you would report if your application is successful).
(b) Outside PCL
We share Recruitment Data with authorised third party service providers to conduct and manage the recruitment process. For example, we may share your Recruitment Data with such service providers in order to conduct screening and verification of your application and the information you have provided to us. This includes verifying academic and professional qualifications. Generally, we will only disclose your Recruitment Data to our suppliers and other third parties in the following circumstances:
- when required to do so by law;
- in response to a legitimate request for assistance by the police or other law enforcement agency; and/or
- to seek legal advice from our external lawyers or in connection with litigation with a third party.
4. HOW LONG WILL WE RETAIN YOUR RECRUITMENT DATA?
We keep your Recruitment Data in accordance with our internal retention policies and procedures. Typically, if you are unsuccessful in your application with us (or if you reject the position), we will keep your Recruitment Data for 9 months unless we have your permission to keep your Recruitment Data on file so that we may contact you again if another suitable position arises – in this situation we will retain such Recruitment Data for 2 years.
5. WHERE DO WE STORE YOUR RECRUITMENT DATA?
Applicants in the European Economic Area (the “EEA”) and the UK should be aware that their Recruitment Data may be transferred to, and stored at, a destination outside the EEA and the UK in countries, which have less strict, or no data protection laws, when compared to those in Europe. It may also be processed by staff or our vendors in other non-EEA jurisdictions which also have less strict or no, data protection laws.
Whenever we transfer your Recruitment Data outside of the EEA or the UK, we will take legally required steps to ensure that adequate safeguards are in place to protect your Recruitment Data and to make sure it is treated securely and in accordance with this Notice. If you are located in the EEA or the UK, you may contact us for a copy of the safeguards which we have put in place to protect your Recruitment Data and privacy rights in these circumstances.
6. EXERCISING YOUR RIGHTS
You may have the right to request access to, rectification or erasure of, the Recruitment Data we hold about you. You may also have the right to object to or restrict certain types of processing of your Recruitment Data and request to receive a machine-readable copy of the Recruitment Data you have provided to us.
If you notice an error in your application that you would like to correct, please contact us using the contact information below.
Any request to exercise one of these rights will be assessed by us on a case-by-case basis. There may be circumstances in which we are not legally required to comply with your request or because of relevant legal exemptions provided for in applicable data protection legislation.
7. CONTACT US
Please contact us at Abian.Sosa@lacostepcl.com if you would like to find out more about any matters relating to this Notice.
If you have concerns about the way in which we have handled your Recruitment Data you should contact us at Abian.Sosa@lacostepcl.com in the first instance. If you are still dissatisfied, you have the right to complain to your Data Protection Authority. In the UK, the Data Protection Authority is the Information Commissioner’s Office.
8. UPDATES TO THIS NOTICE
We may change this Notice from time to time in order to reflect changes in the law, regulatory guidance or our data privacy practices in compliance with the law. When this happens and where required by law, we will provide you with a new or an updated notice detailing how the use of your Recruitment Data is changing and, if necessary, obtain your consent for the further processing.
This Notice was last updated on 13th May 2022.
