Privacy Notice for Job Applicants – ODEON Cinemas Limited (05/06/2019)
Welcome to our privacy notice for job applicants.
About us and our contact details
This document explains how we collect and use your personal data, under data protection laws, as a job applicant. For the purposes of the data protection laws, the ODEON Cinemas Group company which you have applied for a job with, is the controller of the personal data. Our contact details are available in the job application process or on our website.
What data we collect and use
There are a number of reasons why we will need to use your personal data.
We have included further details about:
the types of personal data which we collect and use in appendix 1
reasons why we may use your personal data in appendix 2
We will request and use your personal data on one of the following grounds:
to meet any legal requirements as part of the recruitment process;
for our legitimate interests in the course of our business (where your interests and rights don’t override our business needs);
where we have specifically asked and you have given us permission to use it
If we ask you for your consent to use your personal data, you are free to give, refuse or withdraw it later if you choose to and there won’t be any negative consequences for you.
If you are successful in your application and appointed to a role, the information about you that we collect during the recruitment process will be included in your HR file. Equality Opportunities information which you provide voluntarily will be held separate to your HR file.
Some data you need to give us
There will be some personal data you must give us, whether to meet certain legal, pre-contract or other requirements. Without such information, it could affect our ability to continue our recruitment process with you; or meet our legal obligations. If any personal data we request is optional, we’ll let you know that upfront.
Where we get your data
We collect your personal data through our recruitment process. This includes data coming directly from you, recruitment agencies, background check providers, test providers (including psychometric testing organisations) and your reference providers. We sometimes collect additional information from other third parties (including business partners, networking websites, social media and other public websites, but only to the extent that it would be lawful for us to do so, as part of the recruitment process).
Who we share it with
We may share your personal data with those colleagues involved in the recruitment process (HR administrators, recruiting managers, those colleagues involved in shortlisting and interview panel members).
Where relevant to the application process, we may share personal data with: other members of the ODEON Cinemas Group; service providers (eg recruitment or employment agencies, referees, testing providers (including psychometric testing) and recruitment process related venue providers); external advisors and others as necessary for the purposes we collected it. Where appropriate, we or such third parties, will share details of any applicable privacy notices about their processing of your personal data as either controllers or processors.
To the extent that it is relevant to your job application or our recruitment process, or depending upon the location of our service providers, we may share personal data with people or businesses outside the UK and European Economic Area. We’ll make sure your personal data transferred internationally is secure and protected in accordance with data protection laws.
How long we’ll keep your data
We will only keep your personal data for as long as we need to, for the purposes we collected it for, and to meet any legal, accounting, business or reporting requirements. In some circumstances, we may anonymise your personal data, so that it is unidentifiable and continue to use it. As soon as we no longer need your personal data, (which for unsuccessful candidates would usually be 12 months after the date of our decision) we will securely delete or destroy it.
Where we use automated decision-making
We may use computer systems to check through personal data and make a decision without our colleagues or service provider’s employees being involved. Where we do this, more information on our approach, what it means for you and the safeguards we use are available from the Data Protection Officer (firstname.lastname@example.org).
You can do any of the following in terms of your personal data, in certain circumstances:
ask to see it
ask us to correct it
ask us to delete it
ask us not to process it
ask us to restrict its use
ask us to give you or someone else your personal data in a portable format
change your mind at any time and refuse permission, where we’re relying on your consent to use your personal data
We act with trust & respect in all your requests in respect of the above, and will carry them out as soon as we can. If your request seems excessive or unreasonable, we may need to charge a fee to cover the work involved or we may not agree to your request.
If you’re unhappy with our use of your personal data or have any concerns, we hope that our Data Protection Officer can work this through with you. However, if you remain unhappy you can make a complaint to the Information Commissioner's Office, the UK regulator for data protection issues. (www.ico.org.uk).
This privacy notice is not part of any contract between us and you, and we will update it from time to time. If any such changes will affect you, we’ll let you know. If you want more information or have any questions or concerns, please feel free to contact our Data Protection Officer by email email@example.com .
Appendix 1: types of personal data we capture and use for job applicants
The types of your personal data we use, include:
Personal details: details such as name, title, personal contact details, disability or health status information where needed to make reasonable adjustments for you as part of the recruitment process. Equal opportunities monitoring information.
Documents required under immigration laws: If offered a role you will need to be able to demonstrate that you can legally work in the country for us, such as citizenship and passport documents, details of residency or work permits.
Application information: including details in application letters and CV, work background, education history, professional qualifications and training, language and other relevant skills, any information you provide to us during an interview, and any assessment information (including any psychometric testing) as part of the recruitment process.
Background information: needed to complete a background check (including credit checks for specific finance roles), references and details of unspent criminal convictions.
Other information: CCTV footage, other on-site attendance information, such as visitor sign in sheets. Bank details, where submitting a claim in relation to recruitment expenses.
Appendix 2: reasons for using your personal data
The reasons why we may use your personal data, may include matters related to:
Making decisions about your job application, including performance in any tests and interviews
Checking your right to work in the country*
Making a formal job offer**
Carrying out background and reference checks, where applicable.
Equal opportunities monitoring.
Organising, arranging and managing arrangements for you, or approving expense claims, in connection with the recruitment process.
Managing disability access and reasonable adjustments arrangements*.
Communicating with you about the recruitment process.
Keeping records related to our recruitment process.
Generally, we will use your personal data listed above, on the grounds known in legal terms as our ‘legitimate interests’. Our legitimate interests are those actions where using your personal data is necessary, eg: to run and safeguard our business, to recruit or assess individuals for the benefit of our business. The exceptions are those items above marked: ‘*’ where the reason is to meet our legal obligations; and ‘**’ where the reason is for steps before entering into a contract with you or to perform a contract with you.
Appendix 2 continued
Use of Special Categories of personal data: Certain information, such as equal opportunities information, is optional for you to provide and will not affect your application if you do not provide it. Where you do provide it, we use it in an anonymised manner to produce and monitor equal opportunities statistics.
Information such as disability or health data is used to consider if any adjustments need to be made for you as part of the recruitment process.
Religious and health information may be used with your permission, to meet any of your dietary requirements, should there be any catering arrangements at test centres, interviews or recruitment related meetings.
We may also use your personal data in the course of our business activities, where we are allowed to do so by law. In every case, we will of course safeguard your personal data.