Privacy Policy
WILLIAM GRANT & SONS CANDIDATE PRIVACY NOTICE
1. WHAT IS THE PURPOSE OF THIS DOCUMENT?
This is the "Candidate Privacy Notice" of the William Grant & Sons Group. The privacy notice applies to your application to work for any company within the William Grant & Sons Group of Companies. A current list of companies is attached at Appendix 1.
Each member of the William Grant & Sons Group of Companies is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. You are viewing a copy of this Candidate Privacy Notice because you are applying to work with us as an employee. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment process and your rights in relation to your personal information.
Whilst this Candidate Privacy Notice is intended to describe the broadest range of our information processing activities globally in relation to the recruitment process, these processing activities may be more limited in some countries based on the restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we process that information. In those instances, we adjust our internal policies and practices to reflect the requirements of local law.
2. DATA PROTECTION QUERIES If you have any questions about this Candidate Privacy Notice or how we handle your personal information please contact dataprotection@wgrant.com.
3. THE KIND OF INFORMATION WE HOLD ABOUT YOU
In this Candidate Privacy Notice, ‘your personal information’ means your personal data i.e. information about you from which you can be identified.
In connection with your application for work with us, we may collect, store, and use the following categories of personal information about you (where there is a requirement to do so and in accordance with local laws):
- The information you have provided to us in any CV/covering letter.
- The information you have provided on our application form.
- The information relating to your right to work.
- Any information you provide to us during an interview (or as part of the application process including any relevant testing)
- Information relating to your education/qualifications and employment history, including references
- Information relating to your driving licence
- Information relating to financial background checks
- Information relating to Directorships and any restrictive covenants
We may also collect, store and use the following types of more sensitive personal information (where there is a requirement to do so and in accordance with local laws):
- Information about criminal convictions and offences.
- Information about your race or ethnicity, gender or sexual orientation.
- Information about your fitness for work in a particular role
- Information relating to drugs/alcohol screening tests
- Information about any adjustments required to the recruitment process.
Further information regarding the personal information we process about you is detailed within the table in section 6 below.
4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources (if applicable):
- You, the candidate.
- Any applicable recruitment agency.
- Any applicable third-party background check provider.
- Your named referees.
5. HOW WE WILL PROCESS PERSONAL INFORMATION ABOUT YOU
We may process your personal information during and after the recruitment process. This may include collecting your personal information, recording it, storing it, using it, amending it, destroying it and, in some circumstances, disclosing it.
In general, we will process the personal information we collect about you for the reasons, and on the legal grounds set out in the following table, and also to:
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
- Establish, exercise or defend legal claims.
- Protect your vital interests or those of another person (in exceptional circumstances, such as a medical emergency).
|
Reason for processing your personal information |
Legal ground(s) for processing, and legitimate interest (where applicable) |
Your personal information |
|
Contact you regarding the recruitment process and any offer of employment |
To enter a contract |
Personal contact details (including name, address, email, telephone number) |
|
Make a decision about your recruitment or appointment, including assessing your skills, qualifications and suitability for the employment |
To enter a contract To comply with a legal obligation For our legitimate interests to select suitable employees |
|
|
If you have accepted an offer of employment from us that is subject to such checks (as relevant to each role and local law requirements):
|
To enter a contract To comply with a legal obligation For our legitimate interests to select suitable employees
|
|
|
Determine the terms of any potential contract between you and us |
To enter a contract To comply with a legal obligation |
Offer letter, and proposed contract between you and us |
|
If you have accepted an offer of employment, check you are legally entitled to work in the country where the role is based |
To enter a contract To comply with a legal obligation |
Documentation confirming your right to work in the country where the role is based. With your consent, this may involve a check carried out using biometrics. |
|
Establish whether you can undergo an assessment which forms part of the application process Consider reasonable adjustments to the recruitment process for applicants
|
To enter a contract To comply with a legal obligation For our legitimate interests to select suitable employees *For special categories of information:
|
Information about a disability, the effects of that disability, and special arrangements that may need to be made to the recruitment process as a result of that disability* or any other reason
|
|
Carry out equal opportunities monitoring |
For our legitimate interests to review equality of opportunity or treatment *For special categories of information:
|
The following information you have provided via our equal opportunities monitoring form:
|
6. IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
The table at section 5 above identifies the personal information that we may need to enter into a contract with you. If you fail to provide said personal information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to confirm your employment with us.
7. LEGAL REQUIREMENT TO PROVIDE YOUR PERSONAL INFORMATION
In some circumstances, the provision of your personal information is legal requirement. This includes documentation confirming your right to work in the country where the job is based– if you don’t provide this, we may not be able to progress your application.
8. INFORMATION ABOUT CRIMINAL CONVICTIONS
To enable us to make recruitment decisions and assess suitability for particular work, we may process information about criminal convictions and offences (including alleged offences) as described in this section 8.
We will only process information about criminal convictions where this is allowed in accordance with local laws; and there is a requirement for us to do so or where we think that there is a need to do so to protect our business. You will be notified in advance of any background checks required for the vacancy and you will be asked to consent to these checks in advance.
9. AUTOMATED DECISION-MAKING
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision making in limited situations. You will not be subject to decisions that will have a significant impact on you based solely on automated decision making unless we have a lawful basis for doing so and we have notified you. However, if we use your personal information on an automated basis to make decisions which significantly affect you, you have the right to ask for the decision to be reviewed by an individual to whom you may make representations and contest the decision.
10. DATA SHARING
We will only share your personal information with the following third parties if this is required by law; necessary to enter a contract with you; where there is another legitimate interest in doing so; or where it is necessary to protect your vital interests or those of another person:
- Other entities in the William Grant & Sons Group of companies for the purposes of managing our recruitment process, for example relevant members of the human resources team and the hiring manager(s).
- Third-party providers, including providers of recruitment services; the provider of our recruitment management software tool; providers of aptitude and competency testing; and providers of background checking services including right to work background checking services.
- Former employers if required to obtain references for you.
- Other third parties as necessary to comply with our legal obligations.
11. TRANSFERRING INFORMATION INSIDE AND OUTSIDE THE UK AND EEA
If you are based in the UK or EEA, we may transfer your personal information we collect about you to countries outside the UK or EEA in order to perform our contract with you. To ensure that your personal information receives an adequate level of protection we will put in place appropriate measures to ensure that your personal information is treated by third parties in a way that is consistent with and which respects UK and EEA laws on data protection.
If you are based outside the UK or EEA, we will collect your personal data in line with our global standards and your data will be processed both inside and outside the UK and EEA. To ensure that your personal information receives an adequate level of protection we will put in place appropriate measures to ensure that your personal information is treated by third parties in a way that is consistent with and which respects UK and EEA laws on data protection and any local applicable laws.
12. HOW LONG WILL WE RETAIN YOUR PERSONAL INFORMATION?
We will usually retain your personal information for a period of 6 months after we have communicated to you our decision about whether to appoint you to role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention approach (unless legally we are required to keep this for longer).
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your consent to retain your personal information for a fixed period on that basis.
If you accept employment with us following the recruitment process, we will give you a copy of our Employee Privacy Notice, and will retain your personal information as detailed in the Employee Privacy Notice.
13. YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION
Depending on the country where you live, you may have the following rights:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you along with other relevant information.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request deletion or erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information in certain circumstances. This means we will stop processing your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in a structured, commonly used, machine readable format, in certain circumstances.
- Request to withdraw consent at any time (where processing based on consent).
If you want to exercise any of these rights, please contact our Global Legal Team (dataprotection@wgrant.com). When you submit your request, we may ask for information from you to help us confirm your identity. This ensures that your personal information is not shared with someone who doesn’t need to see it.
14. ANY QUESTIONS OR COMPLAINTS
If you have any questions about this privacy notice or how we handle your personal information, please contact the Global Legal Team (dataprotection@wgrant.com). We’ll do our best to resolve any queries or issues.
If you feel your query hasn’t been resolved, you have the right to make a complaint at any time to the appropriate supervisory authority for data protection in the country where you are based.
If you are based in the UK, the relevant supervisory authority is the Information Commissioner’s Office (ICO). Their contact details can be found online at https://ico.org.uk/.
If you are based in the EEA, the contact details of the supervisory authorities of the EEA member states can be found online at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
15. CHANGES TO THIS PRIVACY NOTICE
This notice does not form part of your employment contract. We may update this notice at any time.
Appendix 1 – List of data controllers
- House of Hazelwood Limited
- Peter Mielzynski Agencies Limited (PMA Canada)
- Quality Spirits International Limited
- Spiritmen Limited
- Tequilera Milagro S.A. De C.V.
- Tullamore Dew Heritage Centre Limited
- Tuthilltown Spirits LLC
- William Grant & Sons (AME) Limited
- William Grant & Sons Americas LLC
- William Grant & Sons Australia PTY Limited
- William Grant & Sons Brands Limited
- William Grant & Sons Colombia S.A.S
- William Grant & Sons Commercial Limited
- William Grant & Sons Cyprus Limited
- William Grant & Sons Deutschland GmbH
- William Grant & Sons Distillers Limited
- William Grant & Sons France
- William Grant & Sons Hong Kong Limited
- William Grant & Sons Inc
- William Grant & Sons India Private Limited
- William Grant & Sons Irish Brands Limited
- William Grant & Sons Irish Manufacturing Limited
- William Grant & Sons Kenya PTY Limited
- William Grant & Sons Korea Limited
- William Grant & Sons Limited
- William Grant & Sons Liquor Trading (Shanghai) Limited
- William Grant & Sons Malaysia
- William Grant & Sons Mexico S.A. de C.V.
- William Grant & Sons Nigeria
- William Grant & Sons Polska Limited sp.Z.o.o
- William Grant & Sons Singapore Pte Ltd
- William Grant & Sons (Taiwan) Co Ltd
- William Grant & Sons (Thailand) Company Limited
- William Grant & Sons UK Limited
- William Grant & Sons Vietnam Company Limited