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Vertu Motors Group Recruitment Privacy Policy
(last updated: April 2018)

Summary

As part of your application to any member of the group of companies of which Vertu Motors plc is the holding company (each company being a “Vertu entity”) we will collect and otherwise process personal information about you in order to consider your application(s) and to administer our relationship with you. This may involve sharing your personal information with third parties. This Privacy Policy describes in detail how we will use your personal information and how you can exercise your rights with respect to your personal information.

If we decide to change this Privacy Policy, we will post the updated Privacy Policy on the Vertu Careers website (www.vertucareers.com) so that you are always aware of what personal information we collect, how we use it and under what circumstances we disclose it. The updated Privacy Policy will take effect as soon as it is posted on the website.

Introduction

In this Privacy Policy, references to we, us or our (or words of similar import) means the Vertu entity that processes your personal information (as defined below) and interacts with you (for example, the entity to which you apply for a role).

The documents you receive from any Vertu entity will identify the relevant Vertu entity that you are dealing with in any particular instance.

These include:


and for the purposes of this Privacy Policy Vertu Motors Plc and the Vertu entities in the same group as Vertu Motors Plc (including those listed above) shall constitute the Vertu Group.

In this Privacy Policy, references to you mean the person whose personal information (as defined below) we collect, use and process.

We are committed to protecting your privacy. We will use your personal information in accordance with the Data Protection Act 1998 up to and including 24 May 2018 and the EU General Data Protection Regulation 2016/679 thereafter (GDPR) (together the Data Protection Legislation). and other applicable laws and regulations that relate to data protection and privacy.

This notice does not form part of any contract of employment or other contract to provide services.

It is important that you read this notice so that you are aware of how and why we are using such information.

Who is responsible for your personal information?

For the purposes of the Data Protection Legislation the relevant Vertu entity is the data controller in respect of your personal information that we collect and process as further described in this Privacy Policy.

We may share your personal information with other organisations that may receive and process your personal information as a data controller in their own right. Please see below for further information.

What information do we collect?

We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), vehicle details, employment history and data collected as part of any application (including previous addresses, employment details and bank account details). This information is referred to in this Privacy Policy as personal information.

In particular, we may collect and process the following personal information about you:


We may also collect, store and use the following “special categories” of more sensitive personal information:


If you provide us with personal information about another person, you must ensure that before you provide us with their personal information, you have their agreement to do so and that they are aware of the ways in which we use personal information as set out in this Privacy Policy.

How is your personal information collected?

We collect personal information about prospective recruits 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, credit reference agencies or other background check agencies.

How do we use your personal information?

We use your personal information in connection with our business activities. In particular, we may use your personal information in the following ways:


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

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to consider your application and/or to manage your employment with us, and 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 listed below.


Some of the above 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 make a decision about your recruitment or appointment, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

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.

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.

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:


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.

Our obligations in recruitment

We will use your particularly sensitive personal information in the following ways:

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. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your recruitment that you agree to any future request for consent from us.

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, where it is necessary 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.

We envisage that we will hold information about 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 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 your recruitment.

AUTOMATED DECISION-MAKING

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

DATA SHARING

We will share your information in the Vertu Group. We may have to share your data with other 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 EEA. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you 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 entities within our group. The following activities are carried out by third-party service providers: pension administration, benefits provision and administration, IT services.

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

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

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

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.

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. 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 are not offered employment with the company we will retain your information for 2 years from your last contact with us and will then securely destroy your personal information in accordance with applicable laws and regulations.

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 is accurate and current. Please keep us informed if your personal information changes during the recruitment process.

Your rights in connection with personal information

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


If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact datacontroller@vertumotors.com.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, 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 access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT

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. To withdraw your consent, please contact the Data Protection Officer. 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.

DATA PROTECTION OFFICER

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO on datacontroller@vertumotors.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.