What is the purpose of this document?
As part of any recruitment process, the Company collects and processes personal data relating to job applicants. The Company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
This notice applies to job applicants. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.
It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
Lactalis Groupin the UK is made up of different legal entities, including:
- Lactalis McLelland
- Caledonian Cheese Company
- McLelland Cheese Packing
- Fresh Milk Company
- Lubborn Cheese
- Lactalis Nestle Chilled Dairy
This privacy notice is issued on behalf of the Lactalis Group in the UK so when we mention “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Lactalis Group in the UK responsible for processing your data. We may transfer your data between the Group companies where necessary to consider your application for employment, where we are legally obliged to do so or where it is in our legitimate interests to do so.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
What information does the Company collect?
The Company collects a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- whether or not you have a disability for which the Company needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.
We may also collect, store and use the following “special categories” of more sensitive personal information:
- information about medical or health conditions, including whether or not you have a disability for which the Company needs to make reasonable adjustments; and
- Information about criminal convictions and offences.
The Company collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including testing which may be either on-line or conducted in-house.
The Company will also collect personal data about you from third parties, such as references supplied by former employers and information from employment background check providers. The Company will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does the Company process personal data?
The Company needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, the Company needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
The Company has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the Company to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may do this, provided your interests and fundamental rights do not override those interests. The Company may also need to process data from job applicants to respond to and defend against legal claims.
The Company processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where the Company processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.
If your application is unsuccessful, the Company will keep your personal data on file in case there are future employment opportunities for which you may be suited. The Company will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.
Who has access to data?
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
The Company will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The Company will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks.
The Company will not transfer your data outside the European Economic Area.
How does the Company protect data?
The Company takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. Please refer to our internal policies for more detail of the controls in place, eg: systems restrictions.
For how long does the Company keep data?
If your application for employment is unsuccessful, the Company will hold your data on file for 12 months after the end of the relevant recruitment process. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new Privacy Notice.
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request;
- require the Company to change incorrect or incomplete data;
- require the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing; and
- ask the Company to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the Company’s legitimate grounds for processing data.
[If you would like to exercise any of these rights, please contact your HR Representative. You can make a subject access request by completing the Company’s form for making a subject access request.
If you believe that the Company has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the Company during the recruitment process. However, if you do not provide the information, the Company may not be able to process your application properly or at all.
You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.
Recruitment processes are not based solely on automated decision-making.