Candidate Privacy Notice
Publicis Communications Candidate Privacy Notice
1. What is the purpose of this document?
Publicis Communications (which includes Leo Burnett, Fallon Saatchi & Saatchi, Publicis London, Poke, Arc, August, Salterbaxter, Turner Duckworth, Prodigous, MSL) is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. This privacy notice applies to you if 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).
2. Data protection principles
We will comply with the applicable data protection law and principles, such as the GDPR, 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.
3. 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, qualifications.
- Any information you provide to us during an interview.
We may also collect, store and use the following "special categories" of more sensitive personal information:
- Information about your health, including any medical condition, health and sickness records.
- Information about criminal convictions and offences.
4. How is your personal information collected?
We collect personal information about candidates from the following sources:
- You, the candidate.
- Recruitment agencies that you, the candidate, have provided your data to, which have introduced you to us.
- Publicly accessible sources such as Linkedin
- Publicis employee referral schemes
- Your named referees from whom we collect the following categories of data: job title, dates of employment.
- Third party background check provider, if applicable.
5. 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 role (or work).
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Communicate with hiring / interviewing managers during the process
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
- Contact you about future roles, if appropriate.
It is in our legitimate interests to decide whether to appoint you to the role (or work) since it would be beneficial to our business to appoint someone to that role (or to carry out that work) or other appropriate roles (or work) that you would be suitable to be considered for during the 12 months after communicating with you about the specific role (or work) that you’ve applied for.
We also need to process your personal information to decide whether to enter into a contract (or the provision of services or employment) with you.
Having received your CV and covering letter or your application form 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 role (or work). If we decide to offer you the role (or work), we will look to obtain references.
6. 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.
7. 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 will use your particularly sensitive personal information as employer only 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 the interview process.
- We will use information about criminical convictions and offences as set out below.
8. Information about criminal convictions
We do not envisage that we will process information about criminal convictions.
However, there may be specific roles where we we will collect information about your criminal convictions history if we would like to offer you the role (or work) (conditional on checks and any other conditions, such as references being satisfactory). If we are required to carry out a criminal records check we will let you know. We may need to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular if the specific role (or work) requires a high degree of trust and integrity and so we would like to 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.
9. Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
10. 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: recruiters, hiring managers, interviewers, HR and staffing teams, other agencies within Publicis Communications, our candidate database provider and background check provider. 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.
We may transfer your personal information outside of the EU. In the event that your data is transferred outside of the EU we will ensure that your personal information receives an adequate level of protection by having a valid transfer mechanism in place so that your personal information is treated by such third parties in a way that is consistent with and which respects the EU and UK laws on data protection.
11. 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 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.
12. Data retention
How long will you use my information for?
We will retain your personal information for a period of 12 months months after we have communicated to you our decision about whether to appoint you to the role (or work). 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 also retain your data for this period because another opportunity may arise during this period which you may be suitable for. After this period, we will securely destroy your personal information in accordance with our data retention policy. If we wish to maintain your personal information on file for longer than 12 months, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
Where a successful candidate is sponsored for visa purposes by us and your CV was considered as part of the recruitment process for this role, we keep your CV and recruitment details (as set out above) for a period of 6 years from the appointment of the successful candidate or at least a year after the successful candidate’s employment with us terminates (whichever is the later). We retain your personal information for this period in the event that the Home Office carry out an immigration audit.
13. 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 the recruitment process and during the retention period:
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 request that via an email to email@example.com.
If you have any questions about this privacy notice or how we handle your personal information, please contact us via email at firstname.lastname@example.org. 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.
For details on how we use your personal information, see our Privacy Notice.