Terms & conditions

N Brown Pre-employment Privacy Policy

This Privacy Policy sets out how we collect and use your personal information and what your individual data protection and privacy rights are.

This Privacy Policy was last updated on 21 May 2018 and is version 1.0.


Who is Responsible for Processing Your Personal Data
JD Williams & Company Ltd trading as N Brown is the Data Controller. This is the legal entity responsible for how your personal data is collected, stored and processed.

Managing Your Personal Data
When you share your personal data with us, you have a right to expect that information to be treated with total confidentiality. Therefore, it is our responsibility to manage your personal data that you provide to us with care, in accordance with all data protection legislation and industry best practice.

It is your responsibility to ensure that your personal data provided to us is accurate and up to date.

Personal data means information relating to a living individual, such as job applicants, who can be identified from that data and other personal information which we hold. This can include name, address, email address, gender, financial information, CCTV images, next of kin names and contact details, sickness information, aliases, amongst other things.

There are also special categories of personal data about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (or non-membership), genetic data, biometric data for the purpose of uniquely identify a person, data concerning physical or mental health or condition, sexual life, criminal offences, or related proceedings.

Most often we may process these special categories of personal data where we need to carry out our legal obligations or exercise rights in connection with employment, where the processing is necessary for the assessment of your working capacity or where it is needed in the public interest (such as equal opportunities monitoring). In exceptional circumstances we may process this data with your explicit consent.

Whether you have supplied your personal data online, by phone, by email or on paper, we will never use it without a lawful reason to do so. We will use your personal data for the purposes for which they were initially requested and as fully explained in this Privacy Policy.

Your personal data will only be shared with the appropriate individuals or teams across the business, solely for the purposes of processing your personal data as outlined in this Privacy Policy or for the purposes of investigating issues where they arise. These include People Team representatives, or the appropriate managers involved in the recruitment process, and Site Security.

When we process special categories of personal data it is only shared in exceptional circumstances and with your explicit consent. Appropriate checks and safeguards are in place to ensure your confidentiality.

Retention of Your Personal Data
We keep your personal employment files in hard copy and soft/online format.

We will only retain your personal data 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 data are available on request from people.service@jdwilliams.co.uk.

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.

Using Your Personal Data When You Apply for a Job
As part of the recruitment and on-boarding process we collect and process personal data that is necessary for us to take steps to enter into a contract of employment with you. This information is used to assess your eligibility for employment, suitability for the role, equal opportunities monitoring and to make the offer of employment.

Applying for a Job and Making an Offer of Employment to You
Your personal data, such as name, email address, telephone number, address, and curriculum Vitae (CV) are collected through our 3rd party applicant tracking system. This information is used during the recruitment period to make contact with you, to assist in the assessment of your suitability for the role and to make the offer of employment. The information is retained on the recruitment system for a period of 12 months, at which time it will be archived unless you opt to retain it.

If you become an employee of N brown, a copy of your CV will be retained on your employment file along with any interview notes that have been taken. If your application is unsuccessful or you decline an offer of employment, these will be destroyed after 6 months.

Pre-Employment Screening
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 legal obligations and provided we do so in line with our Criminal Record Check Policy, this is available on request from people.service@jdwilliams.co.uk.

We will only collect information about criminal convictions if it is appropriate, given the nature of the role you are being recruited for or hold and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions 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 in the following ways:

  • To prevent fraud and to protect our customer and employee personal data;
  • To comply with our legal and regulatory obligations;
  • Where we are allowed to use your personal data in this way to carry out our regulatory obligations; to conduct the criminal record checks as necessary for the purpose of a protective function, which is intended to protect members of the public against dishonesty, malpractice or other seriously improper conduct; and to exercise our obligations or rights which are imposed or conferred by law in connection with employment, social security or social protection law; and
  • Where we have in place an appropriate policy and safeguards, which we are required by law to maintain when processing such criminal conviction data.

  • Any details arising from the criminal record check are not kept on your file. We use an approved 3rd party to carry out ours checks and they holds the details on their system for 2 years.

    Right to Work in the UK
    Under the Immigration Act 2016, we are obligated by law to ascertain your right to work in the UK before we make an offer of employment to you. To comply with this law we obtain and keep copies of appropriate documentation, which evidences your right to work in the UK. This can include copies of your passport or your long form birth certificate with supporting evidence of your National Insurance Number.

    If your application is unsuccessful, or you decline an offer of employment, this documentation is securely destroyed.

    Psychometric Evaluation or Skill Tests
    As part of the application process you may be required to psychometric or skills tests, these may be administered by an external 3rd party. If you become an employee of N brown, a paper copy of the results of these tests will be retained on your employment file. If your application is unsuccessful or you decline an offer of employment, the paper copy will be destroyed after 6 months. The results for all applicants are held with the 3rd part testing provider for a 12 month period before they are deleted.

    Using Your Personal Data for Equal Opportunities Monitoring
    As part of the recruitment process, we collect special categories of personal data such as religious beliefs and ethnicity. This information is recorded separately and is not linked to any other personal data held by us and is therefore anonymous. This information is used for equal opportunities monitoring in the recruitment process in an aggregated and anonymised form.

    Using Your Personal Data for Your Personal & Company Security
    We have a legitimate business interest to process your personal data where it is done so to maintain the security of you, our employees, the business and its systems. This information will include your name and photographic or video imagery.

    CCTV
    We operate CCTV cameras on all sites for legitimate business purposes, such as:
  • to deter and/or detect criminal acts against people, buildings and assets and provide evidence to the police or other authority for the purposes of investigation/prosecution of crimes;
  • to support and promote a robust Health and Safety culture; and
  • to assist and promote effective management of all Sites.

  • Video recordings from the CCTV cameras are kept for 90 days and might be shared internally with internal teams such as the People Team or third parties such as the police as part of any investigation where the recording are used as evidence.

    The NBrown CCTV Policy is available on request from people.service@jdwilliams.co.uk.

    Using Your Personal Data to Process Insurance Claims & Legal Disputes
    We may be required to process your personal data where it is necessary for compliance with a legal obligation in relation to a company insurance claim or a legal dispute, for example:
  • to handle an claim or dispute against the business
  • to handle claims against the business regarding personal injury

  • Sharing Your Personal Data with Third Party Processors & Partners
    As part of your relationship with us, to fulfil our contractual or legal obligations, we will share your personal data with carefully chosen third party processors and partners who carry out a number of services on our behalf. Should you wish to obtain a list of our latest third party processors and partners, you can request this at any time by contacting our Data Governance team.

    Any third party that communicates with you on our behalf must only do so for the purpose of carrying out the services and not for the purpose of direct marketing their own products and services. If you have any concerns about any of our third party processors and partners, please contact our Data Governance team.

    Processing Your Personal Data Outside of the EU
    We may transfer the personal data we collect about you with third parties outside the European Economic Area (the EEA) to 3rd parties as outlined elsewhere in this policy, please also see Sharing Your Personal Data with Third Party Processors & Partners. In some cases, countries outside the EEA may not have such well-developed data protection laws as those in the EEA. However, we will put in place measures and safeguards that require your personal data to be kept secure, confidential and to be processed only and strictly in line with the terms of this Privacy Policy and any relevant data protection laws.

    How to Contact Us
    If you have any questions, comments or complaints about this Privacy Policy or our use of your personal data, please contact us at:
    Data Governance Team
    JD Williams and Company Limited trading as N Brown
    Griffin House
    40 Lever Street
    Manchester
    M60 6ES
    informationrequest@nbrown.co.uk.
    Tel: 0161 2382123

    If you are at all dissatisfied with the information provided by the Data Governance Team, please address any complaints to the Data Protection Officer at the same address.


    Your Personal Data Rights

    Right of Access
    You may wish to access a copy of the personal data we hold about you - known as a Subject Access Request. You can do so by ringing, writing to or emailing the Data Governance team. We will respond to your Subject Access Request as soon as possible and, in any event, within the statutory 30 days. However, in the event that we need more time from you to verify your identity, which we must do to ensure we disclose your personal data to the right person, the 30 day response period will only commence from the time we have validated your identity.

    Right of Rectification
    If you believe we have made an error as to the personal data we hold about you, please email careers@nbrown.co.uk and we will be able to assist you.

    Right of Erasure
    You have the right to request your personal data to be permanently deleted from our records and systems to avoid any further communication with you. Your request will always be considered in light of the legal bases that we hold, store and process your personal data and the purpose that we collected your data. Where the legal bases permits, we will carry out your instruction without undue delay. Where we have a legal basis for processing your information, we may not be able to carry out your request but we will explain this fully to you. Please address any request to delete your data to the Data Governance team.

    Right to Restrict Processing
    Should you believe that we are processing your personal data in a way that you did not understand or agree to and wish to restrict such processing, please contact to the Data Governance team who will be able to assist you.

    Right to Object to Processing
    You have the right to object to certain types of processing of your personal data. We will always make it clear at the outset of any new arrangement with you how we are going to process your personal data. Should you wish to object to such processing, we will give you the option to opt out on application. However, should you wish to discuss this matter further, please contact to the Data Governance team.

    Right to Portability
    You are entitled to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format.

    Whilst, you have the right to transmit the personal data to another data controller, without hindrance where the processing is based on consent or the processing is carried out by automated means. Should you wish to discuss this matter further, please speak to the Data Governance team.

    Right to be Informed
    You have the right to be informed about the collection and use of your personal data. This is commonly known as a ‘privacy statement’ or ‘privacy policy’. We will provide you with the information about how we collect and use your data in various means, such as by ‘just in time’ notice provided to you at the time of collecting your personal data and via this Privacy Policy. Our Privacy Policy is regularly reviewed in line with our business processes. Any changes to this Privacy Policy will be communicated via email and on Our Hub. You can ask for a printed copy of our Privacy Policy by contacting people.service@jdwilliams.co.uk.

    Right to Complain to the Information Commissioner’s Office (ICO)
    You have a right to lodge a complaint with the Information Commissioner’s Officer (ICO) if you have a complaint with how you believe your personal data has been handled. For more information, please visit https://ico.org.uk/concerns