Privacy policy
What is the purpose of this document?
Mediaworks is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in relation to any application you make to work for or with us, in accordance with the General Data Protection Regulation (GDPR).
In most cases Mediaworks is a “data controller” in relation to the personal data of any candidates applying to work for/with us. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
Where we engage a “data processor” to process your personal data on our behalf, we will enter into a written agreement to ensure that the relevant data processor complies with the law and has appropriate safeguards in place to protect your personal data.
You've been provided with this privacy notice because you're applying to work for/with Mediaworks, whether as an employee, worker or contractor and those applying for work experience. It's important that you read this notice, so that you're aware of how we use your personal data. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must 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
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.
In connection with your application to work for/with Mediaworks, we may collect, store, and use the following categories of personal information about you:
Any information that you provide in your curriculum vitae (CV) and covering letter; Any information that you provide as part of your application, including your name, title, address, telephone number, personal email address, date of birth, gender, employment history, photographs, videos, membership of any professional body and training / qualifications; Any information that you provide during an interview; Any information that you disclose during a phone call with HR or the relevant recruitment manager; Any information found on your personal LinkedIn profile; Any information from the results of any competency assessments that you may be required to complete as part of the application process; Any other information that you disclose during or after the application process; Any feedback or scores on your application; And/or any information relating to your immigration and right to work status, if applicable.
In isolation, some of the above information may not constitute personal data, however – when combined with other information – the same may become information from which you can be identified. Therefore, the above information has been included within this privacy notice. Where you are successful with your application – and when you begin your work with Mediaworks – you will be provided with a separate privacy notice, which specifically relates to how we collect, store, and use your personal data during and after your working relationship.
We may also collect, store, and use the following “special categories” 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; Information about criminal convictions and offences where relevant to the role for which you are applying.
Please see the relevant sections below for details of how we use more sensitive personal information.
How is your personal information collected?
We may collect personal information about you through:
The application and recruitment process, where that information is provided by you, whether orally or in writing (including any documents that you provide to us); From a recruitment or employment agency and/or job board, if applicable; Credit reference agencies or other background check agencies, if applicable; Disclosure and Barring Service in the UK in respect of criminal convictions, or the equivalent body in other jurisdictions, if applicable; Your named referees, whose consent you will have obtained prior to disclosing their personal data to us; Employee referral, where we request the referrer to obtain your permission; Your personal LinkedIn profile or other such publicly held work related information.
How we use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
To assess your skills, qualifications, and suitability for the role; To carry out background and reference checks, where applicable; To communicate with you about the recruitment process; To keep records related to our hiring processes; To comply with legal or regulatory requirements; To improve our recruitment, employment, and equality and diversity policies and practices; To protect Mediaworks from fraud or illegal activities; and/or to ensure the health and safety of the workplace.
Generally, our recruitment process means that initially we will use the following sources to ascertain whether you are a suitable candidate:
Your CV; Covering letter; Application form; Your personal LinkedIn profile; and/or any results from the assessment tests which you have participated in.
If we deem you to be a suitable candidate, you will be invited for an interview. The information that you provide us at your interview together with the information collected by us at the initial stage will be used to determine whether we make an offer of employment to you. Thereafter, and before confirming your appointment, we may take up references and carry out any other relevant checks, including criminal record checks, where applicable.
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to pursue legitimate interests of our own to decide whether to appoint you to the advertised role or equivalent role within Mediaworks, and that it is necessary to take such steps, at your request, prior to entering into a contract with you.
The situations in which we will process your personal information are listed below;
Making decisions about your suitability for the role advertised or another role within Mediaworks; Making a decision about the education, training and development requirements; Making a decision about your recruitment or appointment; Determining the terms on which you work for us; Checking you are legally entitled to work in the UK and/or Ireland; Equal opportunities monitoring.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide personal information
If you fail to provide certain information when requested, and where such information is necessary for us to consider your application, e.g. evidence of qualifications or work history, we may not be able to process your application.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How we use particularly sensitive personal information
”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
In limited circumstances, with your explicit written consent.
Where we need to carry out our legal obligations and in line with our Policy.
Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme, and in line with our Policy.
Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.
Our obligations as an employer
We will use your particularly sensitive personal information in the following ways:
We may use 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, or any other aspect of the recruitment process.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
Information about criminal convictions
For most roles that we advertise, we will not process information about criminal convictions, other than if you voluntarily disclose such convictions as part of your application. However, for certain roles, we may need to conduct a basic criminal records check. If you have applied for a role requiring a criminal records check, we will only collect information about your criminal conditions history if we would like to offer you the role conditional upon checks and any other conditions, such as references, being satisfactory. The criminal record check will only be made where it is required to satisfy us that there is nothing in your criminal convictions history which makes you unsuitable for the role; in particular where the role requires a high degree of trust and integrity (i.e., it involves customer data, company data, company finances or other commercially sensitive information), we would like to ask you to seek a basic disclosure of your criminal records history. The legal basis we rely upon for this type of processing is that it is within our legitimate interests to check the suitability of its staff for certain roles, especially those which require us to access customer data. Moreover, as an additional condition, we also rely upon your consent to process such data and we will not process such data without your consent. We have in place an appropriate policy document and safeguards in place when processing such data, as required by law.
Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- Where we have notified you of the decision and given you 21 days to request a reconsideration.
- In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
- If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
- You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless we have a lawful basis for doing so and we have notified you.
Data sharing
We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer your application or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
”Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities may be carried out by third-party service providers: storage and management of candidate and application data, communication with candidates on behalf of Mediaworks, credit and reference checks where applicable.
How secure is my information with third-party service providers and other entities in our group?
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.
When might you share my personal information with other entities in the group?
We will share your personal information with other entities in our group if it is necessary to complete the recruitment process, for example, if you have applied for or expressed an interest in a role within one or more of the group’s entities.
Data security
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
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. Details of these measures may be obtained from our Chief Financial Officer, Mark Rutherford.
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?
Where you have provided consent as part of your application, we will retain your personal information for 24 months. If we wish to retain your personal data after that, on the basis that a further opportunity may arise in future that we may wish to consider you for, we will contact you separately, seeking your explicit consent to retain your personal data for a fixed period on that basis.
Where you have not provided consent at the application stage, we will contact you after 5 days seeking your explicit consent to retain your personal data. If you do not provide consent we will retain your personal information for 30 days, after which it will be deleted. We may be unable to progress your application in this event.
No personal data disclosed during any criminal records check will be kept after the recruitment process, other than whether the criminal records check result was satisfactory or not.
We retain your personal data for the above 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. After the above period, we will securely destroy your personal data in accordance with applicable laws and regulations.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of access, correction, erasure and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your application process.
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 makes 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 Group People Director in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
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.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Group People Director. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law
Data protection officer
We have appointed Mark Rutherford (CFO) as our Data Protection Compliance Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact Mark Rutherford. 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.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time.
If you have any questions about this privacy notice, please contact the Group People Director or email [email protected]