Candidate Privacy Notice
Introduction
As part of our recruitment process, Stella McCartney and its affiliates collect and process personal data from job applicants. We care about your privacy and want you to be familiar with how we collect, use and disclose information.
We also aim to ensure that all times we comply with the local requirements of data protection law.
We are Stella McCartney Limited, a company registered at 3 Olaf Street, London, W11 4BE (company number 04169969), referred to in this Privacy Notice together with our affiliates listed below, as ‘SMC’.
- Stella McCartney Italy S.R.L registered at Via Morimondo 2/3 20143 Milan, Milano, Italy (company number 02339380483)
- Stella McCartney France S.A.S registered at 15 rue Cassette 75006 PARIS,(company number 441 532 504)
- Stella McCartney Spain S.L registered at Paseo de Gracia 56, 6ta Planta, Puerta B, 08007 Barcelona, España, with (company number B65795825)
- Stella McCartney Shanghai Limited Unit registered at 3903-3905, Plaza 66 Tower 2 No. 1266 Nanjing Road West Shanghai 200040 Shanghai China (company number 91310000585281687E)
- Stella McCartney Hong Kong Limited registered at Unit B122, 16/F, Tower 5, Gateway Harbour City Kowloon Hong Kong
- Stella McCartney Japan Limited registered at H2 AOYAMA Building, 5-10-1 Minami Aoyama Tokyo, Tokyo 1070062 Japan
- Stella McCartney America Inc, registered at State of Delaware c/o The Corporation Trust Company (registered agent), 1209 Orange Street, Wilmington, Delaware 19801, County of New Castle
Stella McCartney Limited and the local Stella McCartney company you are applying to are the "data controller" and responsible for your personal data.
We collect a range of information about you. This may include:
- your name, title, address and contact details, including home address, email address and telephone number, nationality, civil/marital status, date of birth, gender;
- information about your right to work in the country where the vacancy is;
- details of your education, qualifications, skills, experience and employment history;
- information from interviews and phone-screenings you may have;
- information about your current level of remuneration, including benefit entitlements;
- references and, for positions in the Finance Department, results of pre-employment screening checks (e.g. credit history, criminal records checks where permitted under local law);
We may collect this information in a variety of ways. For example, data might be contained in application forms you submit or your CV (including when these are sent to us as part of speculative applications or queries), obtained from your passport or other identity documents, or collected through interviews or other methods of assessment.
We may also collect personal data about you from third parties, such as references supplied by former employers, recruitment agencies, business partners, background-screening agencies as well as from publicly available sources such as social media profiles.
We use your personal data for recruitment and business management reasons including identifying and evaluating candidates for potential employment and maintaining our business records in relation to recruitment and hiring. We use your personal data for this purpose on the legal grounds of taking steps at your request prior to entering into a contract of employment between you and SMC and our legitimate interests in hiring appropriate persons and maintaining records of our recruitment practices, including so that we may contact you in the future if a suitable vacancy arises, except where such interests are overridden by your interests or fundamental rights and freedoms.
We may also process certain of your personal data to comply with certain legal obligations which SMC is subject to, for example, checking that you have the right to work in the country in which the vacancy is located or to protect our legal rights to the extent authorised or permitted by law.
We will not use your personal data other than for recruitment purposes, unless we are required to do so by law, or unless you consent to its use.
We may also collect “special categories of personal data” (a term the GDPR uses for more sensitive categories of personal data) for equal opportunities monitoring purposes in countries where this is permitted, including information about your ethnic origin, sexual orientation, health and religion or belief.
Other than as set out below, special categories of personal data are under no circumstances shared with recruiters and managers and are only used for diversity reporting purposes after being anonymised.
SMC may also process information about whether or not candidates are with disabilities or health conditions so that we can make reasonable adjustments where appropriate. We process this personal data on the legal ground of carrying out our obligations and/or so that you or SMC may exercise legal rights related to employment or (only where applicable) to enable us to establish, exercise or defend legal claims.
We will only process special categories of personal data related to criminal convictions and offences or related security measures where we have obtained your explicit consent or where permitted by applicable law (and then only when necessary for the purposes of assessing your suitability for a role).
The processing of legal or criminal records data will be undertaken in compliance with applicable laws and in specific circumstances (e.g., for final round candidates for positions in the Finance Department). The legal basis for such processing will be necessity for compliance with a legal obligation and the Company’s legitimate interests in hiring, for roles involving the regular handling of significant assets, persons who have proven their reliability and probity.
our personal data will be accessible to the SMC People and Culture team and persons who will be involved in the selection process (both for the role you have applied for and other opportunities we think you may be suitable for). This includes sharing your personal data with trusted external HR consultants where appropriate. Depending on the role you have applied for, we may also need to share your job application data with the local SMC affiliate where you may work and countries in which we have central operations. All SMC personnel have an obligation to treat your personal data in strict confidence.
We may share certain personal data with relevant external parties, for example to check references.
We may share your personal information with third parties for the purposes of processing your application, for example:
- A recruitment agency or search consultancy with whom you have registered or instructed to feedback on interviews or to process your applicable;
- A third party provider of skills, aptitude or psychometric testing used in the selection process;
- the provider of our online recruitment platform and other third party providers of recruitment software; and
- Background screening agencies.
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, as a data processor, for the purposes of providing services to SMC and in accordance with our instructions.
This may involve the transfer of your personal data from your country of residence to third parties in other countries, some of which are located outside the European Economic Area (“EEA”). Where we transfer your personal information outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal information will be protected by us in the EEA. This can be done in a number of ways, for instance the country that we send the information to might be approved by the European Commission; or the recipient may have signed up to a contract based on “Standard Contractual Clauses” approved by the European Commission, obliging them to protect your personal information. In other circumstances, the law may permit us to transfer your personal information outside the EEA. In all cases, however, we will ensure that any transfer of your personal information is compliant with applicable data protection law.
We may also share personal data with third parties in connection with a potential or actual sale of our business or assets and, where relevant, we will respond to requests for personal data where required to do so by law, or when we believe that disclosure is necessary to protect our legal rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.
We have adopted physical, technical and administrative security measures to protect personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access. To protect your personal data outside the limits of our recruitment platforms or our control, your device should be protected (such as by updated antivirus systems) and your internet service provider should take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
All our third-party service providers are required to implement appropriate security measures to protect your personal information in line with data protection laws.
Please remember that while we take reasonable steps to protect your personal data, the transmission of personal data over the Internet (including email) is not 100% secure. You accept the inherent security implications of dealing on-line over the Internet and will not hold us responsible for any data breach unless it is due to our negligence.
If we decide not to hire you, we will retain your personal data for up to 2 years unless you are applying for a role in Italy, in which case we will retain your personal data for up to 5 years.
During this period we may write to you from time to time with updates regarding our recruitment process or to invite you to apply for roles we think you are suitable for.
At the end of that period, your data will be deleted or destroyed. You can request your personal data to be deleted or destroyed sooner through your candidate account on our recruitment platform or by emailing us at [email protected].
Where permissible, we will retain some or all of your personal data for exercising or defending legal claims, for a period of time corresponding to the applicable statute of limitations, or legal or regulatory obligations.
If your application is successful, personal data gathered during the recruitment process will be transferred from your candidate record to your employee record. During your onboarding, you will receive our Employee Privacy Notice with further details.
You have a number of rights in relation to your personal data including the right:
- to be informed about how your personal data is used (as we have explained in this Notice);
- to request access to and receive a copy of the personal data we hold about you (this is also known as a data subject access request);
- to request that we correct any inaccuracies in your personal data;
- in certain circumstances, to request that we delete your personal data or restrict processing of your personal data;
- in certain circumstances, to move, copy or transfer personal information you have provided to us (this is also known as the right to data portability);
- to object to use of your personal data based on our legitimate interests; and
- where we are using your personal data with your consent, to withdraw your consent.
Please note that in certain circumstances there may legal reasons why we cannot, or decide not, to comply with your request to exercise these rights. Should this be the case you have the right to complain to your local supervisory authority listed in the table below. These supervisory authorities often have lots of information on their website to help you to understand your rights in relation to your personal data.
United Kingdom
Information Commission’s Office (ICO)
www.ico.org.uk
registration number: Z9393260
Italy
Garante per la protezione dei dati personali
Address
Piazza Venezia n. 11 - 00187 Roma
www.garanteprivacy.it
Centralino telefonico: (+39) 06.696771
https://www.garanteprivacy.it/home/modulistica-e-servizi-online
France
CNIL
https://www.cnil.fr/
Spain
Agencia Española de Protección de Datos (“AEPD”)
www.aepd.es
China
The Cyberspace Administration of China (CAC) or relevant administrative authorities under Personal Information Protection Law
www.cac.gov.cn
Hong Kong
Office of the Privacy Commissioner for Personal Data, Hong Kong
http://www.pcpd.org.hk/
Japan
Ministry of Health, Labour and Welfare (for personal information related to employment)
https://www.mhlw.go.jp/otoiawase/index.html
Personal Information Protection Commission (PPC)
https://www.ppc.go.jp/index.html
United States of America
There is no data protection authority as such, however, the relevant state Attorney General is responsible for data protection matters.
If you have any questions or would like to exercise any of your rights in respect of your personal data, please email [email protected]
Please note that we may require proof of identity before responding to you.
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application.
We may occasionally change this Notice, for example, to comply with new requirements imposed by the applicable laws or technical requirements. We will post the updated Notice on our website stellamccartney.com