This privacy notice (Privacy Notice), sets out the ways in which HACHETTE UK LIMITED and its associated companies which are part of the Hachette UK Group of companies and the UK companies within the Lagardère SCA Group, use and share personal data (your Personal Information) of candidates who apply for jobs within our companies (“you”) It also explains what rights you have to access or change your personal data.
Hachette UK Limited or the Hachette UK Group company which is carrying out the recruitment activity is the data controller which means that this company will decide how your personal information is held, used and protected. We are required under Data Protection Law to notify you of the information set out in this Privacy Notice.
This Notice applies to personal data of job candidates and potential candidates for employment and any recruitment events or recruitment programs. It does not apply to any personal data of employees or independent contractors or authors or customers of the Company.
It applies to any personal data submitted by an application by post or in an on-line application such as an application tacking system or via a third party recruitment agency.
Please read this notice and keep it together with any other privacy notice you may be provided with when we collect or process your personal information about you.
This Privacy Notice sets out your rights under data protection laws which are the Data Protection Act 2018 and any successor legislation and, from 25 May 2018, and as long as EU law remains in force in the UK, the EU General Data Protection Regulation 2016.
We take your privacy and our responsibility to protect your information seriously.
WHO WE ARE
Hachette UK Limited is a company registered in England under company number 2020173, with its registered address as set out below. We are part of the Hachette UK Group of companies
You can contact us as follows:
FAO: Legal Department (GDPR)
Address: Carmelite House, 50 Victoria Embankment, London EC4Y 0DZ, UK
COMPLIANCE WITH DATA PROTECTION PRINCIPLES
We will comply with all applicable data protection laws.
Under the Data Protection principles contained in the GDPR the personal information we hold about you must be:
used lawfully, fairly and in a transparent way
collected only for a valid purpose that has been clearly explained to you and not used in a way that is incompatible with these purposes
relevant to the purposes you have been informed about and limited to these purposes
accurate and kept up to date
kept only as long as necessary for the purposes you have been informed of
WHAT INFORMATION WE COLLECT ABOUT YOU
Personal information means any information about a living individual from which that individual can be identified. The information you provide to us might include:
Your name, postal address, email address, phone number, (contact details)
Date of birth
Marital status and dependents
Details of your educational history, qualifications, skills, experience and employment history
Test results of any tests you agree to take in relation to the application for a job with our company
Your current salary or remuneration and benefits, where provided by candidate
Leaving date and reason for leaving
Your entitlement to work in the UK
Location of previous employment and workplace
Copy of passport and driving license
Recruitment information, CV, copies of any right to work in the UK documents, and cover letters, references or previous employers
Special Category Information
If you provide us with more sensitive information, known as Special Category (“Sensitive”) information and may include details about a person’s racial or ethnic origin, political opinions, religious, philosophical or similar beliefs, trade union membership, genetics, biometrics, health, sexual life, sexual orientation or about criminal offences or proceedings. We will explain why we are collecting this and it will only be used where you have given your explicit consent or for various purposes which include the performance of your contract, our legal obligations and other legitimate interests set out in this Privacy Notice.
We may collect and use the following Special Category information about you:
Information about your health which may include mental or physical health, disability and your medical condition, health or sick records prior to your employment or engagement
Information about your race, or national or ethnic origin, religious, philosophical or moral beliefs, your sexual life or sexual orientation philosophical beliefs, disability for example where you provide these to us voluntarily in a survey or via our applicant tracking system
Information about criminal convictions or criminal offences where the law allows us to do so including DBS checks where these are relevant
HOW WE COLLECT INFORMATION
We collect your information during the recruitment process directly from you or from a recruitment agency or background check provider where these are used
Information we receive from third parties:
We may sometimes collect information from third parties such as:
recruitment agencies, former employers, credit references agencies or other background check agencies, other company employees who have interviewed you.
Medical practitioners where appropriate
Information about how you use our website and apps:
We will also collect certain information about how you use our website and apps such as application tracking systems and the devices that you use to access them. Our website may include links to third party websites, plug-ins and applications. By clicking on those links or enabling these connections you may allow third parties to collect or share data about you. We do not control these websites and are not responsible for their privacy notices. Please ensure that you read the privacy notices on any such external websites.
HOW WE USE INFORMATION ABOUT YOU
We use your information lawfully. We do not sell your information to third parties. However we may share your information as set out in the section ‘When we share your information’. The details of how we use your information and the legal bases for our use are set out below:
Where it is necessary in order to perform our contract with you:
to administer your job application
to contact you in case of any other suitable vacancies
to pay you and provide you with any remuneration in accordance with your contract
to make decisions about your continued employment or engagement
Where it is necessary to comply with a legal obligation
to check you are legally entitled to work on the UK
to ascertain your fitness to work
to respond to requests for information required by the Government
equal opportunities monitoring
Where it is necessary for our ‘legitimate business interests’ (legitimate interests) or those of a third party and your interests and fundamental rights do not override those interests. This means our legitimate interests in conducting and managing our business and our employment or working relationship with you.
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing you have rights and choices which include the right to object (please see the section headed ‘Your Rights and Choices’).
We may use your information for the purposes listed below on the basis of our legitimate interests:
to process any job applications you submit to us
to work with our third party recruitment agency to process any job applications you submit to us
to decide whether to recruit you
to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees
to detect and prevent fraud and unauthorised access or illegal activity
to operate a safe and lawful business where we have a legal obligation
We will process special category data in the following cases:
Where we need to carry our legal obligation in relation to your application
Where needed in the public interest or needed to protect your interest or someone else’s interests and you are not capable of giving your consent we may process this type of information
Where it is needed for the public interest such as for equal opportunities monitoring or for your occupational pension scheme
Where you have given your explicit consent
We will use information about your race or national or ethnic origin, religious philosophical or moral beliefs or your sexual life or sexual orientation to ensure meaningful equal opportunities monitoring and reporting
we will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, or to assess appropriate workplace adjustments.
we may also process it where you have already made the information public
If you do not provide personal information:
If you fail to provide certain personal information when requested we may not be able to perform our contract with you. In some case we may be prevented from performing our legal obligations such as health and safety
WHO CAN SEE YOUR INFORMATION
Your information may be processed by our staff or by the staff of third parties we work with to deliver our business. Processing can mean any activity that involves the use of information about someone that can identify them. All uses, for example, obtaining, recording, storing, disclosing, organising, retrieving, deleting and destroying are types of data processing. We take measures to ensure that third parties processing your information on our behalf are acting lawfully in accordance with our instructions and are subject to appropriate confidentiality requirements. We also have adequate technical and organisational safeguards in place in our company and with third party processors to protect your information. Third party processors of your information include:
our website hosts and operators, IT support providers, database operators, site analytics providers and software developers
our courtiers and delivery services
our auditors, technical consultants and legal advisors
our fraud detection services
WHEN WE SHARE YOUR INFORMATION
We may share your information within the companies that make up the Hachette UK group of companies as well as with our parent company and their parent company.
We may share your personal information with third party service providers who carry out the following activities:
any prospective seller or buyer of businesses or assets, only in the event that we decide to acquire, transfer or sell any business or assets
any other third parties (including legal or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law or where we have a legal obligation to do so
Before we share your information we require third parties to enter into an agreement committing to processing the data only in accordance with our written instructions, to maintain appropriate security measures in place to protect your information to protect your information from unauthorised access, processing or use and not to sue the information for their own purposes.
HOW WE LOOK AFTER YOUR INFORMATION
We look for opportunities to minimise the amount of personal information we hold about you. Where appropriate we anonymise and pseudonymise your information. It is held in electronic and paper form. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
ensuring the physical security of our offices, or other sites
ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption
maintaining a data protection policy for, and delivering data protection training to, our employees
limiting access to your personal information to those in our company who need to use it in the course of their work
HOW LONG WE KEEP IT FOR
We will retain your information during the term of your interaction with us or for as long as we reasonably require to retain the information for our legitimate interests, such as for the purposes of exercising our legal rights.
Save where information is provided via the on line application tracking system as described in the section below, we retain information relating to the applications of unsuccessful candidates in any recruitment for six months after the start date of the successful candidate. This includes application forms, letters, cvs, interview scoring sheets and any recruitment related correspondence. This is to enable providing references and to ensure that relevant information is available for any post-employment or post contract query relating to HMRC or Employment litigation.
If you are successful, your information will be kept along with any other employee related personal information you provide us in your personnel records for the duration of your employment with us and for seven years (7) after this date in accordance with the company Privacy Notice.
Where you have provided your personal information via our on line application tracking system, we will retain information stored on your candidate profile for 12 months, at which point we will send you an email reminder asking you to review your account, update your personal information and decide whether you want to keep your account active with us. Any candidates with idle accounts that have not opted to keep their account open will have their data anonymised. This unidentifiable data will be used for reporting and auditing purposes by the HR team.
INTERNATIONAL TRANSFERS OF YOUR INFORMATION
Whenever we transfer your personal information out of the European Economic Area (EEA) we will take all steps necessary to ensure that it is adequately protected and processed in accordance with this Privacy Notice by using all appropriate cross-border transfer safeguards where there is not an adequacy decision from the EU Commission in place, such as:
by entering into the European Commission's Standard Contractual Clauses with the provider which give personal data the same protection it has in the EEA; and
Please contact Human Resources if you would like additional information on the specific means used by us when transferring your personal data outside of the EEA.
AUTOMATED DECISION MAKING
Automated Decision Making occurs when personal information is used by an electronic system to make a decision without human intervention for example where a computer reviews applications.
You will not be subject to automated decisions which have a significant impact on you based solely on automated means unless we have a lawful basis for doing so and have notified you.
We do not envisage making any decisions about you by automated means but we will notify you in writing if this position changes.
KEEPING THE INFORMATION UP TO DATE AND ACCURATE
Please keep us informed if your personal information changes during the terms of your application. This is important so we can ensure that the information we hold about you is correct and up date.
YOUR RIGHTS AND CHOICES
You have choices and rights in respect of the information that we hold about you, including:
Your right to request access to the information that we hold about you (“data subject access request or DSAR) This is the right to receive a copy of any information we hold about you in a structured, commonly-used, machine readable format or in another format of your choice;
You will not have to pay a fee to obtain access to your information unless your request is clearly unfounded or excessive. In such case a reasonable fee may be charged. We may require you to provide us with information to help confirm your identity and ensure your right to access the information. This is to make sure that the personal data is disclosed to a person lawfully
This right can be exercised by contacting us at firstname.lastname@example.org or by sending us a written request by post to Carmelite House 50 Victoria Embankment, London EC4Y 0DZ, UK for the attention of [Legal] HR
Your right to ask us, in certain circumstances, to delete information we hold about you;
Your right to ask us correct information we hold about you if it is inaccurate or incomplete;
Your right to ask us, in certain circumstances to restrict processing of your information.
Your right to request that we transfer your information to another service provider in a structured, commonly used, machine-readable format;
Your right to Object
You have the right to object to our using your information for direct marketing and on the basis of our legitimate interests (refer to section ‘How we use your information’ above to see when we are relying on our legitimate interests). If you want to do this you can contact us using the details in the section ‘Who we are’.
Your right to withdraw Consent
The right to withdraw your consent for our use of your information in reliance of your consent (refer to section ‘How we use your information’ to see when we are relying on your consent), which you can do by contacting us using any of the details in the section ‘Who we are’.
You have the right to receive a copy of any information we hold about you in a structured, commonly-used, machine readable format or in another format of your choice;
You may exercise your rights and choices by contacting us using the details above in the Who We Are section.
You can also prevent processing for marketing activities by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing.
All the above rights may be exercised by contacting us at contacting us at email@example.com or by sending us a written request by post to Carmelite House 50 Victoria Embankment, London EC4Y 0DZ, UK for the attention of [Legal] HR
Your right to Complain
Please contact us if you have any questions or are unhappy about the way your information is used. We hope we will be able to resolve any problems or issues you may.
You also have the right to lodge a complaint about us and our use of your information to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence.
CHANGES TO THIS PRIVACY NOTICE
We may make changes to this Privacy Notice from time to time. We will post any changes on Novel, the company intranet site
This Privacy Notice was issued on 22 May 2018.