SMG Data protection privacy notice (recruitment)
We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on:
- the personal information we collect about you;
- what we do with your information; and
- who your information might be shared with
We are required to provide this information to you in accordance with the General Data Protection Regulation (GDPR).
Who collects the information
SMG (UK) Limited and SMG Europe Holdings Limited (together ‘SMG’) is a ‘data controller’ and gathers and uses certain information about you. This information may also be used by our group companies, including CGC Events Limited and SMG (a Pennsylvania General Partnership) (our ‘group companies’) and so, in this notice, references to ‘we’ or ‘us’ mean SMG and our group companies.
About the information we collect and hold
We may collect the following information from the initial application stage up to when we make a final decision to recruit:
- your name and contact details (ie address, home and mobile phone numbers, email address);
- details and information in relation to your qualifications, experience, employment history (including job titles, remuneration including salary, benefit entitlement, and working hours) and interests;
- your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs;
- information regarding your criminal record including information in criminal records certificates;
- details of your referees and information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers;
- your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
- information about your entitlement to work in the United Kingdom;
- for equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief;
- whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process; and
- a copy of your driving licence.
How we collect information
We may collect this information from you, your referees (details of whom you will have provided), your education provider, any relevant professional body, the Disclosure and Barring Service (DBS) and the Home Office.
The organisation 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 online tests.
The organisation will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. The organisation 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 may be stored in a variety of formats (eg soft and hard copy) in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why we collect the information and how we use it
The organisation needs to process data to assess your suitability as a candidate for a role with SMG.
In some cases, the organisation 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 organisation 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 organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.
Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
The organisation 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 organisation 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.
For some roles, the organisation is obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
The organisation will not use your data for any purpose other than the recruitment exercise for which you have applied.
We seek to ensure that our information collection and processing is always fair and proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
How we may share the information
Your information may be shared internally and externally for the purposes of the recruitment exercise. This includes members of the SMG HR and recruitment team, third party agencies, 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 organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
Your data may be transferred outside the European Economic Area (EEA) to manage the recruitment process. Data may be transferred outside the EEA to SMG’s parent company, SMG (Pennsylvania General Partnership) and/or the private equity investment firm which is the ultimate owner of SMG; Onex Corporation. Both SMG and Onex have appropriate technical and organisational safeguarding measures in place to protect personal data in their possession.
We may also need to share some of the above categories of personal information with other parties, including our professional advisers such as external employment lawyers. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations and are obligated to implement appropriate technical and organisational measures to ensure the security of the data. We may also be required to share some personal information with third parties (for example the Home Office) to comply with the law.
How long we keep your information
We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.
If your application is unsuccessful, the organisation will hold your data on file for a reasonable time period after the end of the relevant recruitment process.
We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination, after which time they will be securely destroyed. If there is a valid business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised.
If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment.
Keeping your data secure
We have appropriate security measures in place to prevent your personal information being accidentally lost, or used or accessed in an unauthorised way. We also limit access to your personal information to those who have a genuine business need to know it. Some of the technical and organisational measures we use to safeguard your personal data are:
- storing your personal data, in all forms, in a secure environment;
- training our staff on the importance of data protection measures; and
- securing our network by an advanced firewall supported by industry standard anti-virus software.
We also have policies and procedures in place to deal with any suspected data breach so that we can act quickly to minimise any potential damage.
Your rights to correct and access your information and to ask for it to be erased
If you would like to correct or request access to information that we hold relating to you, or if you have any questions about this notice, please contact us using the contact details below. You have the right to object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing. You also have the right to ask us for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. Please contact us using the details below if you wish to exercise this right and we will provide you with further information.
Changes to this privacy notice
This privacy notice was first published on 14 May 2018 and last updated on that date.
Your privacy is important to us and we are constantly reviewing our policies and procedures to ensure we are meeting the high standards we set ourselves. As a result, we may amend this privacy notice from time to time, and we recommend that you check our website periodically to review any changes that may have been made.
How to contact us
If you have any questions or concerns about this privacy notice or the information we hold about you, please do not hesitate to contact us by one of the following methods:
Privacy Enquiries, CGC Events Ltd, Supreme House, Lotherton Way, Garforth Industrial Estate, Garforth, Leeds, LS25 2JY
By e mail:
0113 287 6387
If you would like this notice in another format (for example, audio, large print, braille) please contact us using any of the methods above.