Legal notices

Recruitment Privacy Notice

This Privacy Notice ("Notice") tells you how Liberty Retail Limited of 210-220 Regent Street Mayfair, London, England, W1B 5AH ("Liberty", "we" or "us") processes your personal data. It also describes your data protection rights, including a right to object to some of the processing which Liberty carries out. More information about your rights, and how to exercise them, is set out in the Your Rights section below.

The Information We Collect

We will obtain your personal data because you have submitted an application for a position with Liberty (either directly, through a recruiter, or via our LinkedIn page). This personal data includes, but is not limited to your personal and work contact details, qualifications, CV, employment history, education history, references, candidate assessment (incl. interview notes and telephone screening), ID documentation (incl. passport copy & information, driver's license copy & information). We will hold, use and process that personal data in accordance with the terms of this Notice.

Please do not include any sensitive personal data as part of your application, i.e. information relating to your racial or ethnic origin, political opinions, religious beliefs, trade union membership, health status or sexuality as well as information regarding criminal convictions. If we do require this information in connection with your application, we will inform you separately and obtain any necessary consent from you.

Please ensure you have the informed the Liberty employee or any other referee whose details you provide alongside your application about our use of their personal data as outlined in this Notice.

Verification & Staff Checks

For some positions, it will be necessary for us to verify the details you have supplied (for example, in relation to your identity, academic credentials or your employment history).

The level of required checks will vary by position and will usually be conducted at as late a stage as is practicable in the recruitment process and often only after you have been selected for the position. If your application is successful, we will provide further information about the checks involved and will obtain any necessary consent prior to completing such checks.

How We Use Your Personal Data

We will process your personal data for the following purposes:

As required to enter into and perform the employment contract with you, if your application for a job with Liberty is successful;

> As required to operate our business and to pursue our legitimate interests to: make informed decisions on recruitment and ensure your suitability for the role or to keep you in mind for future roles; answer your enquiries; improve our recruitment processes and activities; manage our IT systems; and conduct group administration. Please note that, we have conducted a careful balancing exercise in order to determine that we can rely on our legitimate interests to justify the purposes described in this paragraph. Please contact us using the details provided below if you would like more information about how we carried out this exercise; and

> In order to comply with applicable laws and the protection of our legitimate business interests and legal rights including but not limited to, use in connection with legal claims, compliance, regulatory, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation). This includes verifying that you have the right to work in the country in which you are applying to a job with Liberty.

If it is mandatory for you to provide information for these purposes, we will make this clear at the time the information is collected and will also explain what will happen if you do not provide the information.

Disclosure of Your Personal Data

Your personal data will be disclosed to:

> subsidiaries and/or affiliates for internal management purposes, and group-wide analytics;

> other third parties who perform services on our behalf such as professional advisors, and IT consultants carrying out management of our IT systems;

> in the event that we are sold or integrated with another business, to our advisers and any prospective purchaser and their advisers; and

> government authorities and/ or regulatory or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

Where We Transfer Your Personal Data

Liberty does not transfer your personal data outside the European Economic Area ("EEA"). 

How Long We Keep Your Personal Data For

If your application is unsuccessful, your contact details will be retained by Liberty for 9 months from the date you submitted your details, for the purpose of matching you with future job opportunities at Liberty. You can request that we stop holding your details for this purpose at any time by contacting us (see the Contact Details section below).

If your application is successful, your details will be transferred to a Liberty personnel file and retained in accordance with the Liberty Data Retention Policy.

Your Rights

Where applicable, you have certain rights under applicable data protection law including the right to ask us for a copy of or update the personal data held about you as well as obtain supporting explanatory materials. You can ask us to make any necessary changes to your information to ensure that it is accurate and up to date or ask us to transfer (or 'port') it to other organisations, or delete it or restrict its processing at your request in certain circumstances.

You also have rights to object to some processing and where we have asked for your consent to process your information, to withdraw your consent by contacting us using the details provided below or using the withdrawal method described when your consent is sought. Where we process your information because we have a legitimate interest in doing so, you also have the right to object to this. These rights are limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your personal data.

Changes to this Notice

If we change the Notice in a material way while we are holding your data, we will notify you of this by email and, if required by applicable local law, we will obtain your consent.

Contact Details

If you wish to exercise any of your legal rights, contact us at: email: humanresources@libertylondon.com or post: 210-220 Regent Street, London, England, W1B 5AH. If you have unresolved concerns, you have the right to complain to the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred. This is most likely to be the Information Commissioner's Office, the data protection authority in the UK.

Last Updated: 18^th June 2018