BLINK BROW BAR LIMITED PRIVACY NOTICE FOR THE RECRUITMENT OF EMPLOYEES, WORKERS, DIRECTORS AND CONSULTANTS

This notice applies to potential new employees, workers, directors and consultants. This notice does not form part of any contract of employment or other contract to provide services. If you are offered and accept an engagement with us you will be provided with a new privacy notice which will replace this one and cover you working for us.

References to we, our or us in this privacy notice are to Blink Brow Bar Limited of 27 Old Gloucester Road, London, WC1N 3AX (Registered number 0655384).

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our HR Advisor has overall responsibility for data protection compliance in our organisation. Contact details are set out in the "Contacting us" section at the end of this privacy notice.

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before and during our recruitment process. This notice explains how we comply with the law on data protection and what your rights are. A separate and replacement privacy notice will be provided to you to cover your working relationship with us if we do recruit you to work for us.

For the purposes of this privacy notice and data protection laws we are the controller of your personal information which we are processing to recruit you.

1. Personal Information

When you interact with us in relation to your work with us, you may provide us with or we may obtain personal information about you, such as information regarding your:

• contact details such as name, title, addresses, telephone numbers, and email addresses;

• date of birth;

• gender;

• marital status and dependants;

• referee details, next of kin, beneficiaries, details of family members and emergency contacts;

• national insurance number and other tax or governmental identifiers;

• bank accounts, payroll and tax status

• salary, bonus, commission, remuneration, annual leave, pension and benefits;

• start date and leaving date;

• location of employment or workplace;

• driving licence(s) (including copies where we are required to hold such information for identification or insurance purposes where you are to use our vehicles);

• identification documents such as passport, utility bills, identity cards, etc;

• recruitment (including copies of right to work documentation, past employment history, references and other information included in a CV or cover letter or as part of the application process);

• work records (including job titles, work history, working hours, training records and professional memberships) and education and professional records/qualifications;

• compensation history and charity donation preferences;

• pension and pension entitlements; and

• images in video and/or photographic form and voice recordings.

=We will always aim to make it clear which personal information it is necessary for you to provide and which personal information is optional. However, if you are unsure as to whether you are required to provide any particular piece of personal information please ask.

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION

We may also collect, store and use the following “special categories” of more sensitive personal information regarding you:

• information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;

• information about your trade union memberships;

• information about your health, including any medical condition, health and sickness records, medical records and health professional information and disability information; and

• biometric information about you, for example fingerprints, retina scans.

We may not collect all of the above types of special category information about you. In relation to the special category personal data that we do process we do so on the basis that:

• the processing is necessary for reasons of substantial public interest, on a lawful basis;

• it is necessary for the establishment, exercise or defence of legal claims;

• it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or

• based on your explicit consent.

In the table below we refer to these as the “special category reasons for processing of your personal data”.

For criminal records information in relation to you we process it on the basis of legal obligations or based on your explicit consent. We do not generally collect criminal records information about you.

3. WHERE WE COLLECT YOUR INFORMATION

We typically collect personal information about employees, workers, directors and consultants through the application and recruitment process, either directly from candidates or sometimes from an employment agency, online recruitment platforms or work related online platforms such as LinkedIn.

We may sometimes collect additional information from third parties including former employers, organisations you have worked for, credit reference agencies or other background check agencies.

If you are providing us with details of referees, next of kin, beneficiaries, family members and emergency contacts they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

4. Uses made of the information

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

Purpose	Personal information used	Lawful basis
Non- ‘special categories’ of Personal Information
Making a decision about your recruitment or appointment and managing the recruitment process and determining the terms on which you work for us	All the personal information we collect for the purposes of the recruitment process excluding ‘special categories’ of personal information and criminal records information	We need this information to be able to perform and administer the recruitment process for you to engage you This is necessary to enter into a contract with you
Checking you are legally entitled to work in the UK	Personal contact details and identification documents and right to work documentation	We have a legal obligation to do so.
Business management and planning, including accounting and auditing, conducting our normal business operations and managing our relationship with you	All your personal information excluding ‘special categories’ of personal information and criminal records information	To be able to manage and perform our contract with you. We have a legitimate interest to run and manage our business
Assessing qualifications for a particular job or task, including decisions about your fitness to work, education, training and development requirements	Personal identifiers, performance, disciplinary and grievance information, employment records, compensation history, salary, annual leave, pension and benefits and other personal information excluding ‘special categories’ of personal information and criminal records information	We may be legally obliged to do so To be able to manage and perform our contract with you We have a legitimate interest to run and manage our business and to ensure that our workers are suitably trained
Complying with health and safety obligations	Personal identifiers, CCTV footage and other working environment information	We have a legal obligation to comply with Health and Safety laws
Retention of your details for use in relation to future opportunities to work for us and future recruitment and sending to you details of future positions	All of the personal information we collect about you excluding special category information and criminal records information	We have a legitimate interest to retain a talent pool in relation to future opportunities and to inform you of opportunities if you have asked us to
Dealing with legal disputes involving you, or other employees, workers, directors and consultants, including accidents	All your personal information excluding ‘special categories’ of personal information and criminal records information	To be able to manage and perform our contract with you We have a legitimate interest to ensure that all legal claims are managed effectively
To ensure network, information and premises security	Personal identifiers and CCTV footage	We have a legitimate interest in ensuring our premises and systems are secure
To conduct data analytics studies to review and better understand worker engagement and retention and attrition rates	Employment or rejection records	We have a legitimate interest in order to improve as an employer
For the purposes of equal opportunities monitoring	Name, title, date of birth; gender; marital status; salary, remuneration, annual leave, pension and benefits; location of employment or workplace	We may have a legal obligation to do so and we have a legitimate interest in doing so to make sure our business is a fair place to work
Storage of records relating to you and also records relating to our business	All non-‘special categories’ of personal information	To be able to manage and fulfil our contract with you, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records
For the purpose of complying with any legal and regulatory requirements	All the personal information about you excluding special category information and criminal records data	We have a legal obligation to comply with legal requirements and we have a legitimate interest in complying with regulatory requirements
‘Special categories’ of Personal Information or criminal records
Storage of records relating to you and also records relating to our business	All ‘special categories’ of personal information	We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above. For criminal records information we process it on the basis of legal obligations or based on your explicit consent.
We will use information relating to your absence from work, which may include sickness absence or family-related absences, to assess whether to engage you	Information about your health, including any medical condition, health and sickness records, medical records and health professional information;	We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work	Information about your health, including any medical condition, health and sickness records, medical records and health professional information	We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above
We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation or political beliefs, to ensure meaningful equal opportunity monitoring and reporting	Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions	We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above
We will use and retain information about criminal convictions to comply with law and in order to determine your eligibility to undertake particular types of work.	Information about your criminal convictions and offences	For criminal records information we process it on the basis of legal obligations or based on your explicit consent.
To comply with our legal obligations and our regulatory obligations	All ‘special categories’ of personal information we collect about you All criminal records information we collect about you	We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above excluding consent For criminal records information we process it on the basis of legal obligations or based on your explicit consent
To manage our relationship with you and to deal with any disputes or claims involving you	All ‘special categories’ of personal information we collect about you All criminal records information we collect about you	We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above For criminal records information we process it on the basis of legal obligations or based on your explicit consent

You are not under any obligation to provide us with any of your personal information, but if you do not provide it then we may not be able to engage you.

You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us. Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the "Contacting us" section below.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to engage you.

5. Who we share your personal information with

We share personal information with the following parties:

• Your recruitment agency(s) or consultant(s): For the purpose of managing the recruitment process

• Our professional advisors: such as lawyers, accountants, consultants and other advisors

• Other service providers to our business: administration and IT services. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.

• Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business.

• The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives, for example HMRC or the Information Commissioner’s Office.

• Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell your data.

6. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

[The personal information we collect is not transferred to and stored in countries outside of the UK and the European Union.]

[The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third part processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws. For further details please contact us by using the details set out in the "Contacting us" section below.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.

7. HOW LONG WE KEEP PERSONAL INFORMATION FOR

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of 12 months if you are unsuccessful in your application to work for us. Exceptions to this rule are:

• CCTV records which are held for no more than 90 days unless we need to preserve the records for the purpose of prevention and detection of crime;

• Information that may be relevant to personal injury claims, employment claims, discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after you have worked for us.

8. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

• the right to be informed about how your personal information is being used;

• the right to access the personal information we hold about you;

• the right to request the correction of inaccurate personal information we hold about you;

• the right to request the erasure of your personal information in certain limited circumstances;

• the right to restrict processing of your personal information where certain requirements are met;

• the right to object to the processing of your personal information;

• the right to request that we transfer elements of your data either to you or another service provider; and

• the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example we do not use automated decision making in relation to your personal data. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

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.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

9. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

10. CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email [enquiries@blinkbrowbar.com or write to us at Blink Brow Bar, 27 Old Gloucester Road, London, WC1N 3AX.