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 up to date 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. DATA PROTECTION PRINCIPLES
In this Candidate Privacy Notice, ‘your personal information’ means your personal data i.e. information about you from which you can be identified. We will comply with applicable data protection law and principles, which means that your personal information will 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.
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
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)
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 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.
5. 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.
6. 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:
|
|
|
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:
|
|
|
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 |
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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:
*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:
*For special categories of information:
|
The following information you have provided via our equal opportunities monitoring form:
|
7. IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
The table at section 6 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.
8. 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 enter into a contract with you.
9. HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
We will use your particularly sensitive personal information in the following ways:
We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during the interview process.
10. INFORMATION ABOUT CRIMINAL CONVICTIONS
To enable us to make recruitment decisions and assess suitability for particular work, we will process information about criminal convictions and offences (including alleged offences) as described in this section 9.
We will only process information about criminal convictions where there is a requirement for us to do so or where we think (within the confines of the law) that there is a need to do so to protect our business. We will process this information to enter a contract with you, to comply with a legal obligation, for our legitimate interests (in selecting suitable employees), and to exercise or perform employment law rights or obligations. 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.
11. 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.
12. DATA SHARING
Why might you share my personal information with third parties?
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.
TribePad, the provider of our recruitment management software tool.
Third party providers, including SHL (aptitude and competency testing) and HireRight (background checking service).
Other third parties as necessary to comply with the law. We require third parties to respect the security of your data and to treat it in accordance with the law. 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.
13. TRANSFERRING INFORMATION INSIDE AND OUTSIDE THE EU
If you are based in the EU, we may transfer your personal information we collect about you to countries outside the EU 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 EU and UK laws on data protection.
If you are based outside the EU, we will collect your personal data in line with our global standards and your data will be processed both inside and outside the EU. 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 EU and UK laws on data protection and any local applicable laws.
14. DATA SECURITY
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. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Compliance Counsel (dataprotection@wgrant.com).
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.
15. DATA RETENTION
How long will you use my information for?
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 explicit 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.
16. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
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 and to check that we are lawfully processing it.
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 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 where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. 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.
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 our Compliance Counsel in writing.
17. COMPLIANCE COUNSEL
We have appointed a Compliance Counsel to oversee compliance with our data protection obligations. If you have any questions about this privacy notice or how we handle your personal information, please contact the Compliance Counsel (dataprotection@wgrant.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.
18. CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time.
APPENDIX
The companies listed below are collectively referred to as “The William Grant & Sons Group of Companies”
Quality Spirits International Limited
Tequilera Milagro S.A. De C.V.
Tullamore Dew Heritage Centre Limited
William Grant & Sons (East) Limited Liability Company
William Grant & Sons (Taiwan) Co Ltd
William Grant & Sons Australia Pty Limited
William Grant & Sons Colombia SAS
William Grant & Sons (Cyprus) Limited
William Grant & Sons Distillers Limited
William Grant & Sons Hong Kong Limited
William Grant & Sons India Private Limited
William Grant & Sons Irish Brands Limited
William Grant & Sons Irish Manufacturing Limited
William Grant & Sons Liquor Trading (Shanghai) Limited
William Grant & Sons Singapore Pte Ltd
William Grant & Sons UK Limited William Grant & Sons (AME) Limited
William Grant & Sons (Thailand) Company Limited
William Grant & Sons Brands Limited
William Grant & Sons Inc
William Grant & Sons Germany
William Grant & Sons France
William Grant & Sons Korea Limited
William Grant & Sons Limited