FOR RECRUITMENT PURPOSES ONLY

APPLICANT PRIVACY NOTICE

What is the purpose of this document?

Marshall Motor Group Limited is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

• Used lawfully, fairly and in a transparent way.

• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

• Relevant to the purposes we have told you about and limited only to those purposes.

• Accurate and kept up to date.

• Kept only as long as necessary for the purposes we have told you about.

• Kept securely.

The kind of information we hold about you

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 curriculum vitae and covering letter.
• The information you have provided on our 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 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, health and sickness records.
• Information about criminal convictions and offences.

How is your personal information collected?

We may collect personal information about candidates 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 will use information about you

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.

It is in our legitimate interests to decide whether to appoint you to the position you are applying for.

We also need to process your personal information to decide whether to enter into a contract of employment or any other contract with you.

Having received your CV, covering letter, your application form and any other supporting information, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the position. If we decide to offer you the position we will then take up references AND/OR carry out a criminal record AND/OR carry out ANY OTHER check before confirming your appointment.

In cases where the appointment is urgent and for legitimate reasons we have not yet obtained all the necessary background checking information, we may permit your employment to commence. However if satisfactory checks are not received within a reasonable time period your employment may be terminated under our Probationary Policy.

If you fail to provide personal information

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 use particularly sensitive personal information

We will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
• We will use information about you to achieve compliance with our regulatory obligations under the Senior Managers & Certification Regime (“SMCR”) and for conducting fit and proper assessments.

Information about criminal convictions

We envisage that we will process information about criminal convictions for some but not all applicants. If you are offered a position as a Senior Manager or a certification employee under the SMCR, we will require information about criminal convictions.

We will collect information about your criminal convictions history if we would like to offer you the position (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.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. Please refer to Schedule 1 of the Employee Privacy Notice for 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.

Data sharing, security & retention

Data sharing - why might you share my personal information with third parties?

We will only share your personal information with the following third parties for the purposes of processing your application such as other companies within the group or with any 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.

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. You are entitled to request the name and address of any third party company or person that we use in this regard and the information will be provided within 7 business days upon receipt of a written request by you or your authorised agent. Details of these measures may be obtained from the HR Director.

We have put in place 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 - how long will you use my information for?

We will retain your personal information for a period of twelve 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.

Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

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.
• 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 (see below).
• 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 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.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the HR Director in writing.

Right to withdraw consent

When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the Recruitment Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

Compliance

The HR Director is responsible for overseeing compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the HR Director (see details contact below).

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

By submitting your application, you are giving your consent to Marshall Motor Group and any company within the group to process your personal and sensitive personal data in accordance with this privacy notice.

Contact details:

Marshall Motor Group
The Quorum
Barnwell Drive
Cambridge
CB5 8RE

Email: compliance@marshall.co.uk