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FOR RECRUITMENT PURPOSES ONLY

JOB APPLICANT PRIVACY NOTICE

ABOUT THIS PRIVACY NOTICE

Marshall Motor Group Limited ("we", "our", "us", “MMG”) is committed to protecting the privacy and security of your personal data.

This privacy notice describes how we collect and use your personal data in the course of applying for work with us.

This notice applies to all applicants, whether successful or unsuccessful in their applications. (Successful applicants will also be provided with a specific Employee Privacy Notice as part of the onboarding process once an offer of employment is accepted.) This notice does not form part of any subsequent 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 Data about you, so that you are aware of how and why we are using such information.

ABOUT US

As a recruiter, Marshall Motor Group Limited is the controller for the personal data that we process that relates to you. This notice describes how we collect and use your personal data during and after your application to work with us.

We are registered with the UK’s supervisory authority, the Information Commissioner’s Office (the “ICO”) with registration number Z6302920.

Our contact information is as follows:

Business name: Marshall Motor Group Limited

Address: Data Protection Office, c/o Marshall Volkswagen Milton Keynes, Greyfriars Court, Milton Keynes, Buckinghamshire, MK10 0BN.

Email: DPOOffice@marshall.co.uk

Data Protection Officer:

We have appointed a Data Protection Officer (“DPO”) to help us monitor internal compliance, inform, and advise on data protection obligations, and act as a point of contact for you and the ICO. If you would like to exercise one of your rights, or you have a question or a complaint about this statement or the way your personal data is processed, you can contact our DPO using the contact details above.

TYPES OF PERSONAL DATA WE COLLECT

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

• The information you have provided to us in your CV, covering letter and/or application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications.

• Any information you provide to us during an interview.

• Information gathered or produced as part of the selection process, including testing and profiling results.

• Information required for our background checking including national insurance number, driving licence details, right to work documents such as passport, financial history and directorships.

We may also collect, store and use the following types of more sensitive personal information:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.

• Information about your health, including any medical condition or health-related issue.

• Information about criminal convictions and offences.

HOW WE COLLECT INFORMATION

We may collect personal information about you from the following sources including:

• You, the candidate.

• Recruitment agencies.

• Background check providers.

• Credit reference agencies.

• Disclosure and Barring Service in respect of criminal convictions.

• Your named referees.

• Previous employers.

• Other third parties who hold information about you either on a public register or database.

HOW WE USE YOUR DATA

We will only use your Personal Data when the law allows us to do so. Most commonly, we will use your Personal Data under the following lawful bases:

a) To take steps to enter into a contract with you and then to perform that contract.

b) To comply with a legal obligation.

c) For our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

d) Where you have given consent to the processing of your Personal Data for one or more specific purposes.

e) Where processing is necessary in order to protect your vital interests or those of another person.

We will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the work and/or the role you are applying for.

• Carry out background and reference checks, including regulatory references where applicable.

• Communicate with you about the recruitment process.

• Keep records related to our hiring processes.

• Comply with legal or regulatory requirements.

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a financial check for this role and you fail to provide us with relevant details, we will not be able to take your application further.

HOW WE PROCESS SENSITIVE INFORMATION

We may use sensitive personal information in the following ways:

• We use information about your disability status to consider whether we need to make appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.

• We may collect and use information about racial or ethnic origin, religious or philosophical beliefs, disability or sexual orientation to ensure meaningful equal opportunity monitoring and reporting.

We envisage that we will process information about criminal convictions for certain roles. We will collect information about your criminal convictions history if we would like to offer you a position which necessitates this (conditional on checks and any other conditions, such as regulatory references, being satisfactory). We are legally obliged to carry out a criminal records check for certain roles in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable. In particular:

• We are legally required by the Financial Conduct Authority to carry out criminal record checks for Senior Managers.

• We have a legitimate interest to carry out criminal records checks for certification employees in order to satisfactorily conduct fit and proper assessments and issue a certificate under SMCR to comply with our regulatory obligations.

• If you are dealing with finance, money, accounting, credit applications and other positions that require a high degree of trust and integrity we may ask you to seek a basic disclosure of your criminal records history.

In the event an offer of employment is made, you will be provided with a copy of our Employee Privacy Notice which will provide more information in this regard.

AUTOMATED DECISION-MAKING

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

THIRD PARTIES

We will only share your personal information with third parties for the purposes of processing your application. These may include other companies within the group or with a recruitment agency, consultancy firm or other company or person that we have employed as our agent or to whom we have outsourced in relation to our recruitment and employment processes and obligations. 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.

TRANSFERRING INFORMATION OUTSIDE UK AND/OR EEA

We may transfer the Personal Data we collect about you outside the UK and/or the EEA. Some countries are deemed to have adequacy as they provide an adequate (i.e. the same or exceeded) level of protection for your Personal Data, other countries require additional measures.

When a country is not deemed as having an adequate level of protection, we have put in place appropriate measures to ensure that your Personal Data is treated by those third parties in a way that is consistent with and which respects Data Protection Laws; for example we mainly rely on the EU Standard Contractual Clauses (SCCs) with the UK Addendum or the UK International Data Transfer Agreement (IDTA). If you require further information about these protective measures, you can request it by contacting us using the details above.

DATA SECURITY

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 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.

DATA RETENTION

We will retain your personal information for a period of 12 months from the date that you submit your application. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. We may also contact you if another position becomes available that you may be interested in applying for.

After this period, we will email you to ask you to ‘opt in’ if you would like your information to be retained. If you do not opt, in your information will be automatically deleted.

YOUR RIGHTS

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which make you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing or you have withdrawn your consent (if applicable).

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

• Where you have consented to the use of your personal data, you have the right to withdraw that consent.

If you would like to exercise any of these rights, please contact our DPO Office using the details provided in this notice.

QUESTIONS, CONCERNS AND COMPLAINTS

The HR Director is responsible for overseeing compliance with this privacy notice. If you have any questions about the recruitment process and how we handle your personal information in relation to this process, please contact careers@marshall.co.uk in the first instance.

If you have any concerns about the handling of your personal data, wish to assert one of your data protection rights, or want to make a complaint, please contact our Data Protection Office at DPOOffice@marshall.co.uk.

If we have been unable to address your concerns or you are dissatisfied with how we have handled your complaint, you can escalate the matter to the ICO via their website at ico.org.uk/make-a-complaint/ or via their helpline on 0303 123 1113.

CHANGES TO THIS NOTICE

This Privacy Notice is reviewed regularly, taking into account changes to legal, regulatory or contractual requirements, changes in working practice or structure to the business.

Changes to this notice may be as a direct result of inputs from audits, security incidents, risk assessments, improvement actions and new objectives that may have been set by MMG management.

Any suggestions on how to improve this notice can be sent to DPOOffice@marshall.co.uk.


Version: 18/06/2026