Privacy Policy
1. OVERVIEW
1.1 This privacy policy covers the use of your personal data by Harding Brothers Retail Limited and Harding Brothers Retail Operations Limited (“Harding”) during our initial stage of recruitment.
1.2 Any references in this privacy policy to “we” or “us” are to Harding. “Personal data” means any information relating to an identified or identifiable individual.
1.3 This privacy policy sets out:
- 1.3.1 What personal data we might collect about you;
- 1.3.2 How we might use that personal data;
- 1.3.3 What personal data we might share with others; and
- 1.3.4 Your rights relating to the personal data we process.
2. WHAT PERSONAL DATA DO WE COLLECT?
2.1 At our initial stage of recruitment, the personal data that we collect, store and process is that which is voluntarily provided to us by you through inputting content on the forms available on this website and through using our online recruitment software. This includes (but is not limited to):
- 2.1.1 Personal data included in your CV;
- 2.1.2 Personal data contained in cover letters you supply;
- 2.1.3 Personal data supplied such as your name, email address & phone number;
- 2.1.4 Any personal data you enter into any application form linked to this site;
- 2.1.5 Any answers to questions that correspond with your recruitment preferences to the extent they comprise personal data; and
- 2.1.6 Any supporting personal data that you provide to expand your candidate profile.
2.2 We may completely anonymise personal data so that you are no longer identifiable from such data and continue to use any such anonymised data. We will use data outside the scope of this privacy policy only when it is anonymised, for example, in order to undertake statistical analysis.
General note: Please note that if you do not provide all the personal data we request, it may not be possible for us to progress your recruitment process.
3. LEGAL BASIS
3.1 We use your personal data through reliance on the lawful basis of legitimate interests in order to:
- 3.1.1 Process your employment application and assess your suitability for the specific job role that you have applied for;
- 3.1.2 Provide you with information relating to your employment application and communicate with you about your application;
- 3.1.3 Communicate with you in regard to recruitment; 3.1.4 Add your details to a searchable candidate database;
3.2 We may also need to request and process your personal data if it is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. This may include the using the personal data that you supply to us in order to verify if you satisfy the requirements for a term of employment, such as an age requirement.
3.3 If we require your consent to process any personal data then we will inform you of this consent requirement, and request such consent, at the point of data entry.
3.4 If we wish to contact you about other similar employment opportunities to the one for which you applied, we will first request your consent.
3.5 If we wish to use your personal data for any purpose unrelated to recruitment, we will first request your consent.
3.6 In some limited cases, we may be subject to a legal obligation in respect of which it is necessary to process your personal data. If this happens, we will only process the personal data necessary pursuant to the relevant requirements.
4. AUTOMATIC DECISION-MAKING
4.1 The personal data that you submit to this site may be subject to automated decision-making solely in respect of your age in order to determine your eligibility for further consideration in respect of recruitment for certain roles. If you do not meet an applicable minimum age requirement, then you will be excluded from consideration automatically.
5. SHARING DATA
5.1 The personal data that you submit to this site may be processed by Harding as the controller and also by our processor, 360 Resourcing, which will collect and store your personal data on our behalf.
5.2 Sometimes your personal data may also be processed on our behalf by other relevant third parties for recruitment purposes. This includes but is not limited to: video interviewing companies, payroll software providers and our payroll agent, and HR software providers.
6. DATA SECURITY
6.1 The technology that we use has been designed with the security of your personal data in mind. We use technical and organisational security measures to ensure a level of security appropriate to any risks posed by the processing. The storage of your personal data in the UK by our processor 360 Resourcing is subject to both suitable technological and operational security measures. Your personal data is only accessed by relevant and authorised personnel.
7. YOUR DATA SUBJECT RIGHTS
7.1 You have the following rights regarding your personal data:
- 7.1.1 Right to information: You have the right to be provided with clear, transparent, and easily understandable information about what personal data is processed, why and by whom it is processed. This is why we are providing you with the information in this privacy policy.
- 7.1.2 Right to access: You have the right to obtain access to your personal data (if we are processing it), and certain other information (similar to that provided in this privacy policy).
- 7.1.3 Right to rectification: You are entitled to have your personal data corrected if it is inaccurate or incomplete.
- 7.1.4 Right to erasure: In certain circumstances you can request for your personal data to be erased from our records. This is not a general right to erasure; there are exceptions.
- 7.1.5 Right to restrict processing: You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your information, but may not use it further.
- 7.1.6 Right to object to processing: You have the right to object to certain types of processing, in certain circumstances. In particular, you have the right to object to the processing of your personal data based on grounds of legitimate interest.
- 7.1.7 Right to object to and not be subject to automated individual decision-making: Subject to some limited exceptions, you also have the right to object to automated processing, including profiling; and not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you.
- 7.1.8 Right to data portability: You have the right to obtain and reuse your personal data in a structured, commonly used, and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
- 7.1.9 Right to withdraw consent: If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful).
8. CONTACT INFORMATION
8.1 To exercise your rights or to contact us with any questions about this privacy policy or about how we handle your personal data, please contact us using: data.protection@hardingretail.com
8.2 You may also make a complaint to the relevant data protection supervisory authority. In the UK, this is the Information Commissioner and further information is available here: https://ico.org.uk/make-a-complaint/
9. LENGTH OF DATA STORAGE
9.1 We do not hold your personal data for longer than is necessary for the purposes of the processing. In general, if there is no activity on your candidate account for 2 years, it will be deactivated and your personal data will be fully anonymised so that you can no longer be identified. It is sometimes necessary to retain employment data for specific periods to satisfy mandatory reporting requirements.
9.2 You can also request to withdraw your details and any application you have made at any time and thereafter your personal data will be fully anonymised so that you can no longer be identified.
10. PRIVACY POLICY CHANGES
10.1 From time to time we may make changes to this privacy policy to ensure that it is accurate and up to date and to reflect any changes in the law. This policy was last updated on 21 June 2021.