PLEASE NOTE: This statement is also available to view online by clicking here.
What is the purpose of this document?
Karro Food Group (we) are committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). It applies to all employees, workers and contractors.
Karro Food Group (and its subsidiaries) is a "data controller". This means that it is responsible for deciding how it holds and uses personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to prospective, current and former employees, workers and contractors. 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.
It is important that you read 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.
Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
The kind of information we hold about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are "special categories" of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you:
We may also collect, store and use the following "special categories" of more sensitive personal information:
How is your personal information collected?
We collect personal information about employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, employment agenices or other background check agencies.
We will collect additional personal information in the course of job-related activities throughout the period of you working for us.
How we will use information about you
Most commonly, we will use your personal information in the following circumstances:
We may also use your personal information in the following situations, which are likely to be rare:
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How We Use Particularly Sensitive Personal Information
"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
Our obligations as an employer
We may use your particularly sensitive personal information in the following ways:
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations as your employer
Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences to assess your suitability for the role (either on recruitment or for offences committed during employment).
Automated decision making
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
We may have to share your data with third parties, including third-party service providers and other entities in the group.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers:
The following third-party service providers process personal information about you for the following purposes: Crown (time and attendance), Openpay (payroll), DotPost (payslip distribution), SHE Assure (Health and Safety), SAP Concur (Expenses), Q-Perm (Permits), Scottish Widows (Pension), Sodexo (Childcare vouchers), Arnold Clark, Mark Garrick and Groundwater(Vehicle Leasing) , Licensing Bureau (Driver Licensing), Canada Life (Life Assurance), BUPA (Healthcare). This list may change from time to time, and will be updated each time the policy is reviewed.
How secure is my information with third-party service providers and other entities in our group?
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. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
When might you share my personal information with other entities in the group?
We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Transferring information outside the EU
We may transfer the personal information we collect about you to the following countries outside the EU: USA in order to perform our contract with you. There is an adequacy decision by the European Commission in respect of that country under the Privacy Shield scheme. This means that the country to which we transfer your data is deemed to provide an adequate level of protection for your personal information.
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
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. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
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.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Generally speaking we retain payroll and all other employment information for seven years from the termination of your employment.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Data Subject Rights
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact [position]. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
The GDPR Team
If you have any questions about this privacy notice or how we handle your personal information, or would like to exercise one of your rights under GDPR, please contact Angela Ireland in Group HR.
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.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact a member of the GDPR Team or HR.
Document Owner and Approval
The GDPR Team are the owners of this document and are responsible for ensuring that this document is reviewed in line with the review requirements stated above. This document is issued by the Group Company Secretary on behalf of the GDPR Team and the Board.
A current version of this document is available on the Karro Food Group intranet and to all members of staff by request from HR.
Signature: Pat Convery, Company Secretary
Change History Record
Description of Change
Date of Issue
21 May 2018
PLEASE NOTE: This is a bullet point summary of our commitments and practices under the GDPR, the full statement can be found below.
We are Workvine Ltd. We provide the software the recruiter uses to manage your application and are the primary "Data Processor" dealing with your application.
For direct recruiters, they are a "Data Controller", for agencies, depending on their recruitment practice, they may be a "Data Controller" (usually for temp role recruitment) or "Data Processor" (usually for permanent roles with an employer).
There may be other data processors involved in the process and you will be informed of their involvement. If we need to, we will ask you before providing these third parties with your data. Some third parties can be passed limited data about you without the need for consent.
When processing an application, we gather the following information as a minimum:
This data is used to enable a recruiter to contact you about the vacancy you've applied to.
When you apply via a job board, sometimes, they send more information than we require. We store this extra information for auditing purposes only. This data may include prior work experience and other employment information you have provided to them in the past.
The Data Controller can ask for further information when processing your application using custom forms defined by them. Custom form data is only ever processed in relation to your application.
For more details on any of these points, please refer to our full GDPR data management statement.
There may be several stages of your application that allow us to process your data in an automated, semi-automated or manual way, each of which is described below.
You will be presented with a form that will ask specific questions relevant to your suitability for the role.
The answers to the questions will be automatically scored using rules set out by a recruiter when they created the vacancy.
If your application cannot proceed based on your answers, you are able to contact the recruiter responsible for the vacancy and request a review of your answers and the outcome using the applicant portal provided.
As part of your application, if you have not provided explicit consent, we may need to ask you for consent later in the process to do something specific to your application.
If we require consent to perform a specific action, we will automatically e-mail you and ask that you provide consent. If you decline or do not provide consent within a pre-defined response time, we will assume that you do not consent and will proceed with your application in a way that is permitted under legitimate interest.
If you are shortlisted for a role, all of the data collected as part of your application up to that point may be made available to one or more hiring managers who will be involved in the decision making process for your application.
In the event of your application being direct to the employer, hiring managers are typically senior staff within the same company.
If this application is via a recruitment agency or other third party agent working on behalf of an employer, the hiring managers will be senior staff from the employers organisation.
We may ask you to provide a number of referees in support of your application. They may be required to attest to your employment, education or character.
Before you provide any details of a referee, you must obtain permission from that referee with regard to your sharing their contact details with us.
During your application, we will want to speak to you on the phone.
You may be contacted by one of our recruiters or a third party agent acting on our behalf who will want to discuss the role with you and your reasons for applying. You may also be asked some specific questions that the employer has set out for the application process.
Workvine Ltd ("Workvine") takes the privacy and security of your information very seriously. This policy explains how and for what purposes we use the information collected about you via the Talentvine Talent Acquisition Platform (referred to below as the “TAP”).
Please read this data management policy carefully.
For the purposes of the GDPR, Workvine is classed as a Data Processor and processes your information on behalf of the Data Controller.
If you have any queries about the policy, please get in touch with us using the contact details set out here and we will do our best to
answer your questions.
Workvine uses the Azure platform from Microsoft to deploy its servers. All of the servers used by the Talentvine platform are restricted to physical locations based in the European Union.
Microsoft and its employees do not have access to any data stored on the Talentvine platform. However, restricted access may be required occasionally to assist with technical issues as they arise.
The TAP is configurable on a client by client basis to collect any data they deem reasonable for the purposes of recruiting individuals to
open positions that they have.
The TAP requires a minimum of information to start an application which is set out below:
The TAP may be configured by the client to request additional information from you in furtherance of your application.
The TAP uses the information you provide to assist our client in the management of the application.
Where our client requires a third party to process your data, we will make the minimal amount of information available for the process to work. Your data may be shared with a third party as part of your application process for the purposes of telephone interview, assessment or background checks.
We have implemented technology and policies to safeguard your privacy from unauthorized access and improper use. We use secure sockets, currently implementing the TLS v1.2 standard to encrypt any personal information you need to input before it is sent to us.
Your password is stored as a one-way hash (a special string of characters mathematically generated using your password as a starting point) using the SHA-512 hashing algorithm which does not contain any trace of your original password. When you login, we re-calculate the hash based on the password you provide and compare it with the hash we store.
All of your data is stored within encrypted databases and on storage mediums with encryption enabled. This is typically referred to as
encryption at rest.
As the data processor, we provide services and facilities that help you to manage your data and exercise your rights according to the GDPR.
These facilities are outlined below:
At any time, you can access your application management portal and withdraw your consent for each application individually. When you withdraw consent, your application will still be processed but under the stricter "Legitimate Interest" clauses of the GDPR.
In addition to the ability to withdraw your consent for individual applications, you can at any time remove either individual applications or all of your data from Talentvine in your account. When you do this, anonymised copies of your applications are retained for reporting purposes.
If you are unhappy with the way your data has been handled, you have the right to complain at any time. If you wish to make a complaint, please contact our Data Protection Officer via our Support portal by emailing firstname.lastname@example.org. You also have the right to lodge complaints with the Information Commissioners Office. Please visit https://ico.org.uk/concerns/ for further information or to start a live chat. Alternatively, you may call the ICO on 0303 123 1113.
When you make your application, we store a one-way hash of your e-mail address against the vacancy to which you apply in order to detect and prevent duplicate applications. This hash is not connected to your personal data and will be retained if you remove an application or your entire account.
When you apply to a vacancy, we calculate a one-way hash of the e-mail address you provide and compare the hash against any previous hashes we have stored for that vacancy. If we find a match using this technique, we prevent the application from being made.
We review the ways we manage your information in accordance with the guidelines and legal requirements set out by the GDPR and other relevant Data Protection acts. Because of these reviews we may change how we manage and store the information collected and who we share it with. Consequently, this privacy notice may be updated from time to time.
Contact us with your views about our privacy practices, or with any enquiry relating to your personal information. You can do so by sending an e-mail to the data officer or write to us at Workvine Ltd, Florence House, St. Mary's Road, Hinckley, LE10 1EQ.
Date : 12/Feb/2018