Value Retail Recruitment Privacy Notice

Recruitment opportunities within Value Retail Management Limited (VRM)and its associated companies may be processed in our online Careers Portal,via recruitment agency or by referral.

You should read through this Privacy Notice (the “Notice”) carefully to fully understand the basis upon which we will use your information, including what information we collect about you, how we use the information, where we store the information and to whom the information is disclosed. Any information that we collect about you that is personal to you, and from which it is possible to identify you, is known as personal data for the purposes of data protection laws.

Commitment to Privacy
We are committed to protecting your personal data and privacy. We will use your personal data for recruitment, onboarding and hiring (if applicable) purposes and as set out in this Notice. We will always keep your personal data safe and comply with any applicable data protection law as amended and updated from time to time.

Other Privacy Notices that may apply

This Notice only applies to information we collect during recruitment and is in addition to our individual privacy notices, which relate to our use of information about you (for example our employee privacy notice which applies to information we collect about you if you commence employment or engagement with us). If you are not willing to accept this Notice or if you do not agree with how we will handle your personal data, please do not sign up to the Portal or provide us with your personal data.

If your personal data has been provided to us by a referee but you no longer wish for us to have or use your personal data please contact us Recruitment@ValueRetail.com.

We work with a number of partner providers, some of whom have their own privacy policies. You can find out more about our partner providers by contacting Recruitment@ValueRetail.com

Who Are We
Please click here to see who we are. The entities listed are the owners or operators of The Bicester Village Shopping Collectors® villages (“Villages”) indicated against their name. References in this Notice to “we” or “us” are to the entities listed.

Each of the entities listed are committed to protecting your privacy and are joint data controllers within the meaning of data protection laws applicable in the UK and European Union (“EU”) and European Economic Area (“EEA”). The entities listed are joint controllers of personal data in order to achieve a universal job application system, supplying job opportunities across the Villages.

Application of this Notice<s/tong>
This Notice applies to the way we collect and process your personal data from the time you provide personal data in a candidate profile, up to the point at which we anonymise the data we hold on you, so that we are unable to tell any data relates to you. Please see section below How long we keep your information for.

Once you commence employment or engagement with us, the way we process your personal data will also be governed by our employee privacy notice (which will be made available to you). Your personnel employee file will automatically be created using information from your portal candidate profile (including any updates you make to your candidate profile). When you make updates to one of your profiles, the other profile will also be updated (if such information is also collected in that profile). For example if you have both a candidate portal profile and an personnel profile and your personnel profile is updated with the time you spent in a job role at Value Retail this will automatically be included in your candidate portal profile. This ensures the data we keep on you is kept up to date.

Candidate Background Screening
Dependant on the position you have applied for, you may be asked to take part in candidate background screening as part of the recruitment process. This service will be carried out by a third -party platform, First Advantage, and involves the upload of your CV and other personal information, which allows us to perform the appropriate checks. For example: employment history, accreditations, ID and criminal records. Should you wish to not take part in the candidate background screening, you must inform us immediately.
__What information do we collect about you?__
As part of the recruitment process, we collect the personal data that you submit to the Portal to create your profile or submit an application, which may include the following (subject to the local legal requirements in the country you apply for a job in):

a) Personal details such as your name, gender, residential address, email address, contact telephone numbers, nationality, or previous criminal convictions;
b) Details about your previous employment such as your curriculum vitae, work history (including whether you have been employed by us before) and any further personal data about you contained therein;
c) Details about your qualifications such as your skills, education, the languages you speak and your proficiency, your eligibility to work in a particular country (e.g. your citizenship or visa details), your experience in particular areas (including management and managing international teams) and industries; and
d) Details about your preferences such as positions you may be interested in, information about when you may be available to interview, start work (i.e. your current notice period) or work on an ongoing basis (e.g. full or part time or on weekends), whether you are open to relocation or working remotely, whether you are willing to travel for work and whether you have your own transport.

Mandatory information : Some information we request is mandatory and must be provided before you can submit an application through the Portal. Any mandatory information will be marked with a red asterisk. If you do not provide any information marked as mandatory, you will not be able to submit an application through the Portal. Other Information : Please note that our application process allows you to include any other information you think relevant to your application, including cover letters, references from your previous employment, and other documents. Please be aware that although we may not require you to provide such documents, they may contain personal data, and we will hold and process any information, including any personal data, that you provide in such documents.

If you click to apply for a position through LinkedIn, we may use the information you have previously provided to LinkedIn, to populate your profile on the Portal (including information regarding your experience, employment, education, skills and recommendations). We will ask you to authorise LinkedIn to share your personal data with us for this purpose.

The data you provide to LinkedIn will only be used to update your profile when you apply to a vacancy using the “apply with LinkedIn” button, it will not automatically update your profile information in between job applications you submit or if you apply for a vacancy without using the “apply with LinkedIn” button. Please note that when you apply for a job using the “apply with LinkedIn” button it is still your responsibility to review the job application before you submit, to ensure all the fields included are correct.

If you apply for a position through an external recruiter or agency, we may collect your information directly from them and contact you directly (if you have given permission to such recruiter or agency to share your information with us).

Automated decision making
Some of our vacancies may have certain pre-requisites relating to lifestyle, working preferences, language abilities, right to work or prior experience. Please note that if the vacancy you apply for has such a pre-requisite, the Portal is configured to automatically reject your application if you do not meet that certain pre-requisite.

How we use your information
We use your personal information in the following ways: Primarily, we use your information in order to consider you for recruitment opportunities with us and to contact you in relation to these, and to progress your application. If your application is successful, we will retain your personal data and process it:
a) For the purposes of onboarding you to your new position; and
b) In the course of your ongoing position (as further set out in our employee privacy policy to which you will have access if your application is successful).

If your application is unsuccessful, we will notify you using the personal data you have provided us.

If you have requested that we send you job alerts, we will also use your personal data in order to inform you about other recruitment opportunities for which you have requested an alert. You can influence the types of opportunities we send you by managing your preferences on your profile page.

We will make your candidate profile visible to our internal company recruiters (whether worldwide, in your country of residence or who manage positions you have applied for, according to the preferences you set) and we will share your personal data internally to make your profile visible. Someone representing the option you have chosen may contact you about your profile, including if we have a vacancy you may be interested in. If you do not agree to this, please see Your Rights below.

How long we keep your information for
Whether your application is successful or not we will retain your personal data on our system for 12 months from the later of (a) the last time you access the Portal, (b) the last time you update your profile in the Portal or (c) the last time you apply for a job in the Portal. Shortly before the 12 month period expires, we will contact you to ask you to update your profile, and to check whether you would like us to retain your personal data or not. If we do not hear from you or you indicate that you no longer want us to retain the personal data in your profile, we will anonymise all personal data we hold on you, so that we are unable to tell any data that relates to you. You are also able to ask us to anonymise your own profile at any time by contacting us using the details here .

However, in some countries we are legally required to retain certain data for longer than this period for legal reasons. Where we are required to retain your details for longer than the period mentioned above (due to local legal reasons) we will anonymise the data as soon as we are no longer required to retain it for such local legal reasons.

Who we share your information with
We share your information between ourselves (see *Who We Are*) for the purposes set out above (see *How We Use Your Information*) We may also provide your information to our suppliers and processors who perform certain business services for us. We share your information with third parties for the purposes of:
a) Administering and providing the Portal including communicating with you regarding other recruitment opportunities;
b) Conducting assessments as part of the recruitment process; and
c) Administering delivery of documents for signature and electronic signatures.

In some cases the information we collect from you may also be processed outside the EEA and such destinations may not have laws which protect your information to the same extent as in the EEA. We have obligations to ensure that your personal data processed by us or by our suppliers or processors operating outside the EEA is treated securely and is protected against unauthorised access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this Statement.

For a list of the suppliers and processors we currently use, how these parties use your information, or details of any processing they perform outside the EEA, and the safeguards that are used to protect your information, please contact Recruitment@ValueRetail.com

In addition, we may disclose your personal data: If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, exchanging information with other companies and organisations for the purposes of fraud protection; and
a) To successors in title or replacement operators of all or part of our respective businesses.

The legal basis for us using your information
We collect and process the personal data referred to above (see *What Information Do We Collect About You?*) on the basis of __consent__, so that we can:
a) Process candidate applications in an efficient, secure and centralised manner;
b) Maximise the number of potential candidates who are informed about opportunities and able to access the application process; and
c) Better understand the way we conduct our recruitment and onboarding practises.

We have assessed the impact of processing your information for the reasons listed above and have balanced your interests, rights and freedoms against our interests in processing your data in this way. This assessment has been used to implement the way we process your data to ensure your rights are adequately protected.

In some cases, we process your personal data in connection with our __legal obligations__.

For example, we may be prohibited by law from employing you if you do not have the right to work in a particular country. We may also be required to make reports to comply with equal opportunities law, which requires us to collect certain information from you (although we make sure that no-one involved in making a decision about your application can see this information).

In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of contacting you about other employment opportunities you may be interested in and carrying out candidate background screening.

Where you have provided consent to us processing your data you have a right to withdraw this (see Your rights).

Your rights
By law, you have a number of rights when it comes to your personal data. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Statement.

Rights	What does this mean?
1.The right to be informed
2.The right of access	You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Statement). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
3.The right to rectification	You are entitled to have your information corrected if it’s inaccurate or incomplete.
4. The right to erasure	This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing	You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability	You may have the right to obtain your personal data and send it to a third party.
7. The right to object to processing	You have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent).
8. The 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). This includes your right to withdraw consent to us using your personal data for marketing purposes.
9. The right to lodge a complaint	You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

Further information and advice about your rights can be obtained from the data protection regulator in your country.

UK
The Information Commissioners’ Office (ICO) https://ico.org.uk/

Ireland
The Data Protection Commissioner (DPC) https://www.dataprotection.ie/docs/Home/4.htm

France
Commission Nationale de l’Informatique et des Libertés (CNIL) https://www.cnil.fr/fr

Italy
Garante per la protezione dei dati personali (Garante) https://www.garanteprivacy.it/web/guest/home

Spain
Agencia Española de Protección de Datos (AEPD) https://www.agpd.es/

Belgium
Gegevensbeschermingsautoriteit (GBA) https://www.gegevensbeschermingsautoriteit.be/

Germany
Data protection for private sector organisations is overseen by regional data protection authorities. Value Retail operates in two regions within Germany and therefore, falls under the jurisdiction of two supervisory authorities.

Bavaria
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA) https://www.lda.bayern.de/de/index.html

Baden-Württemberg
Der Landesbeauftragte für den Datenschutz Baden-Württemberg https://www.baden-wuerttemberg.datenschutz.de/

Contacting us
If you need to contact us for any reason (including to exercise any of your rights in relation to data protection as set out above) please send us your request using the details here. If you need to contact us for reasons related to your application itself please contact us at Recruitment@ValueRetail.com

Changes to this Privacy Notice
We may make changes to this Privacy Notice from time to time. This Notice was updated on 28 April 2021

To ensure that you are always aware of how we use your personal data we will update this Notice from time to time to reflect any changes to our use of your personal data or when we add new services or facilities. We may also update this Notice to comply with changes in applicable law or regulatory requirements. If we make substantial changes to the way we process your personal data we will let you know if this is possible and practical.