What is the purpose of this document?Mitchells & Butlers is made up of different legal entities (the Group), which owns various brands and outlets. Details can be found at www.mbplc.com. This privacy notice is issued by Mitchells & Butlers Leisure Retail Limited (company number 01001181, with its registered office at 27 Fleet Street, Birmingham B3 1JP) on behalf of the Group so when we refer to “we”, “us” or “our” in this privacy notice, we are referring to the relevant company within the Group that is the data controller (the employer company responsible for processing your data).
As a data controller, 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, apprentice, 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).
Contact DetailsWe have appointed a data protection officer (DPO), who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details below:
Data Protection Officer
27 Fleet Street, Birmingham B3 1JP
27 Fleet Street, Birmingham B3 1JP
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the supervisory authority for data protection issues in the UK (phone: 0303 123 1113 or at www.ico.org.uk/concerns). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance.
Changes to this Privacy Notice and Changes to Your DetailsWe will need to update this privacy notice from time to time as the law and/or our business changes and develops. We will endeavour to tell you in advance by sending a service message to you if we hold your email address. Otherwise, please look out for information on our websites and materials that indicates we have changed this privacy notice. If you continue to use our websites and/or services after we have changed our privacy notice, we will take this as an indication that you accept the changes.
It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Data protection principlesWe 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 youIn 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 or via any application process, including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications.
- Notes of any information you provide to us during an interview.
- Results of any tests or assessments that you undertake as part of your application for work with us.
We may also collect, store and use the following "special categories" of more sensitive personal information (Sensitive Personal Information):
- Information about your race or ethnicity. Information about your health, including any medical condition, health and sickness records and any applicable disability information.
- Information about criminal convictions and offences.
How is your personal information collected?We collect personal information about candidates from the following sources:
- You, the candidate.
- Online hiring providers, such as Harri Technologies (UK) Limited and Access UK Limited, from which we may collect your name, email address, phone number, curriculum vitae and cover letter, messages you have sent to these providers as part of your application, your application history, employment history, your location and education and qualification details.
- Certain recruitment agencies and apprenticeship service providers with whom we have relationships, from which we may collect your name, email address, phone number, curriculum vitae and cover letter, messages you have sent to them as part of your application, your application history, employment history, your location and education and qualification details.
- If we decide to undertake such checks, the Disclosure and Barring Service in respect of criminal convictions.
- Your named referees, from whom we collect personal data contained within any reference that they provide us.
How we will use information about youWe will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role.
- Carry out background and reference checks, 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 role since it would be beneficial to our business to appoint someone to that role.
We also need to process your personal information to decide whether to enter into a contract of work with you.
Having received your CV and covering letter and/or your application and the results from any test that you take as part of the application process, 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. If we decide to offer you the role, we may then take up references, carry out a criminal record and/or carry out any other kind of check that we consider necessary before confirming your appointment.
If you fail to provide personal informationIf 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 credit check or references 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 Sensitive Personal InformationWe will use your 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.
Information about criminal convictionsWe will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular when certain roles require a high degree of trust and integrity since they involve dealing with money and/or financial systems. In these circumstances, we would like to ask you for your criminal record history and/or your permission to seek a basic disclosure of your criminal records history.
Where required by law, we have in place an appropriate policy document and safeguards which we maintain when processing such data.
Automated decision-makingWhen you make an application online (for example by utilising the platform provided by Harri Technologies (UK) Limited and/or Access UK Limited) or when you complete certain assessments (for example, around situational judgements) we may utilise automated decision making to assess your application. We apply relatively simple processes (based largely on yes / no responses you provide us and pass/fail results) to create a short list of possible candidates. We need to do this in order to manage our recruitment process effectively and to ensure that all applicants that progress through the process meet our basic requirements for the role in question. The consequence of automated decision-making process will be to determine whether you proceed further in the recruitment process. More information regarding the questions that we may ask you that result in an automated decision being made are set out in the below table.
|Relevant Question / Topic||Our Basis for the Automated Decision-Making Process||Consequence for You|
|It is a legal requirement for individuals to prove their eligibility to work in the UK. Documentary evidence of your right to work in the UK will be required before you commence employment. Which of the following applies to you?
||We are legally required to ensure that you have the right to work in the UK. It is necessary for us to utilise this automated decision-making process, given the potential volume of applications, to make a short list of possible candidates with the intention of entering into a contract with the successful applicant.||If you select “No” to the questions “I do not have the right to work in the UK” you will not proceed further in the recruitment process.|
|Are you aged 18 or over?||It is a requirement of the role with us that involve bar work that you are aged 18 or over. It is necessary for us to utilise this automated decision-making process, given the potential volume of applications, to make a short list of possible candidates with the intention of entering into a contract with the successful applicant.||If you select “No” to this question you will not proceed further in the recruitment process.|
|Are you of school leaving age?||Our policy is to no employ anyone for waiting roles who is not of school leaving age given what is involved in roles with us. It is necessary for us to utilise this automated decision-making process, given the potential volume of applications, to make a short list of possible candidates with the intention of entering into a contract with the successful applicant.||If you select “No” to this question you will not proceed further in the recruitment process.|
|Have you accepted a Fixed Penalty Notice for serving alcohol to somebody under 18 years old during the last 12 months?||Our policy is to no employ anyone who has accepted such a Fixed Penalty Notice given what is involved in roles with us. It is necessary for us to utilise this automated decision-making process, given the potential volume of applications, to make a short list of possible candidates with the intention of entering into a contract with the successful applicant.||If you select “Yes” to this question you will not proceed further in the recruitment process.|
|Do you have any criminal convictions that are unspent under the Rehabilitation of Offenders Act 1974 (including drink driving offences)?||We obtain your explicit consent to use your personal data for the purpose of this automated decision. Your consent is obtained at the point of you completing the application.||If you select “Yes” to this question you will not proceed further in the recruitment process.|
|Do you have a UK bank account or are you able to open one?||We need to ensure that you have, or are able to open, a UK bank account as we need to be able to pay you if you are employed by us and, without a UK bank account, we would not be able to do this. It is necessary for us to utilise this automated decision-making process, given the potential volume of applications, to make a short list of possible candidates with the intention of entering into a contract with the successful applicant.||If you select “No” to this question you will not proceed further in the recruitment process.|
|Situation judgement questions / tests||We may ask you certain situational judgement questions as part of our short-listing for the interview process. It is necessary for us to utilise this automated decision-making process, given the potential volume of applications, to make a short list of possible candidates with the intention of entering into a contract with the successful applicant.||There are pass/fail criteria against these questions and tests and, if you do not meet the pass criteria, you will not proceed further in the recruitment process.|
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 entities in our group and certain providers that are acting for us as part of your application process (such as recruitment agents and recruitment related service providers. 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 securityWe take the security of your personal data very seriously and have in place appropriate security measures at all times, including where we share your information with our suppliers and partners, to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please take care of your own information. For security tips and tricks when using the internet, Wi-Fi and smartphones or tablets, please visit www.getsafeonline.org.
How long will you use my information for?We can only keep your personal data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Unless you explicitly agree otherwise with us (for example, you wish to remain on our records for potential future opportunities for a longer period), we will retain your personal information for a period of 12 months after either we have communicated to you our decision about whether to appoint you to the role or you have deactivated any online account you may have with us in relation to applications (whichever is the latter). 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. After this period, we will securely destroy your personal information in accordance with our data retention policy.
If we wish to retain your personal information on file for a longer period, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately to let you know that we intend to retain your personal information for a fixed period on that basis. You can contact us at that time or at any time afterwards to ask us to remove your information, and we will do so.
We regularly review our retention periods to ensure that we are not keeping your data for longer than necessary. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
Your rights in connection with personal informationUnder 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. You may, in certain circumstances, also have the right to object where we are making automated decisions that significantly affect you.
- 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 our Data Protection Officer in writing.