ODEON Cinemas UK & Ireland – Candidate Privacy Notice – Version: 13 August 2018

Welcome to our candidate privacy notice for job applicants. Our values, our people and best systems & controls are important elements of our growth strategy, called the Big Plan.

  • About us and our contact detail

This document explains how we collect and use your personal data, under data protection laws, as a job applicant.

For the purposes of the data protection laws, the ODEON Cinemas Group company is the Controller (you can find the contact details on the job application or on our website).

  • Our data protection officer

Every territory has a data protection officer (DPO). They are responsible for overseeing everything relating to this privacy notice. Our DPO can be contacted by email:

  • How we'll use your data
  • We follow these simple principles for all of your personal data:
  • we'll tell you how we're going to use your personal data, either when we collect it or via our policies, applications, contracts and other notifications
  • we'll only use it for those reasons or purposes
  • we'll only capture, use, share and keep the minimum information we need
  • we'll keep it accurate and up to date – we'll build in checking processes, and we'll ask you for your help when we need it
  • we'll only keep it for as long as we need to, for the reasons or purposes we explained upfront
  • we'll keep your personal data secure
  • What data we need to collect and use and why

There are a number of reasons why we will need to use your personal data, including:

  • to meet any legal requirements as part of the recruitment process
  • for our legitimate interests in the course of running our business smoothly (where your interests and rights don't override our business needs)
  • where we have specifically asked and you've given us permission to use it

We have included further details about:

  • the types of personal data that we use in appendix 1
  • reasons why we may use your personal data in appendix 2

If we ask you for your consent to use your personal data, you are free to give, refuse or withdraw it later if you choose to. It's fine for you to refuse or withdraw consent later and there won't be any negative consequences for you.

  • Who we share it with

We may share your personal data where necessary, and we'll do this safely and securely. This could be internally with teams such as HR, legal, finance, accounting, security, communications and IT; as well as with certain managers (including those who are working in the department that the role relates to).

To the extent that it is relevant to your job application or our recruitment process, we may share personal data with: other members of the ODEON Cinemas Group; service providers (eg recruitment or employment agencies, referees, background check providers); external advisors and others as necessary for the purposes we collected it.

  • Sharing internationally

To the extent that it is relevant to your job application or our recruitment process, we may share personal data with people or businesses outside the UK and European Economic Area. We'll make sure your personal data is secure and protected. Further details available from our DPO.

  • How long we'll keep your data

We will only keep your personal data for as long as we need to, for the purposes we collected it for, and to meet any legal, accounting, business or reporting requirements. In some circumstances, we may anonymise your personal data, so that it is unidentifiable and continue to use it. As soon as we no longer need your personal data (which for unsuccessful candidates would usually be six months after the date of our decision, unless required for legal purposes), we will securely delete or destroy it. More information is available from our DPO.

  • Your rights

You can do any of the following in terms of your personal data, in certain circumstances:

  • ask to see it
  • ask us to correct it
  • ask us to delete it
  • ask us not to process it
  • ask us to restrict its use
  • ask us to give you or someone else your personal data in a portable format
  • change your mind at any time and refuse permission, where we're relying on your consent to use your personal data

We act with trust & respect in all your requests in terms of the above, and will carry them out as soon as we can. If your request seems excessive or unreasonable, we may need to charge a fee to cover the work involved or we may not agree to your request.

The ICO has provided some useful guidance to explain more about your above rights, so please feel free to consult its guidance for more information:

  • Where we get your data

We collect your personal data through our recruitment process. It comes directly from you or a recruitment agency or background check provider. We sometimes collect additional information from third parties, (including business partners, networking websites, social media and other public websites) but only to the extent that it would be lawful for us to do so, as part of the recruitment process.

  • Some data you need to give us

There will be some personal data you must give us, to meet certain legal and pre-contract requirements. Without such information, it could affect our ability to continue your application or our recruitment process with you, or meet our legal obligations. If any personal data we request is optional, we'll let you know that upfront.

  • Where we use automated decision-making

We may use computer systems to check through personal data and make a decision without a colleague or contractor involved, where appropriate. More information on the logic involved, what it means for you and the safeguards we use are available from the DPO.

  • General

This privacy notice is not part of any contract between us and you, and we will update it from time to time. If any such changes will affect you, we'll let you know when we do. If you want more information or have any questions or concerns, please feel free to contact our DPO.

Appendix 1: types of personal data we capture and use

The types of your personal data we use, include:

  • Personal details: details such as name, title, personal contact details, government identification numbers, disability or health status and details, photographs, and certain data collection required by law
  • Documents required under immigration laws: to demonstrate that you can legally work in the country for us, such as citizenship and passport data, details of residency or work permits
  • Financial information: e.g. your P45 from a previous employer, financial and tax information
  • Application information: including details in application letters and CV, work background, education history, professional qualifications and training, language and other relevant skills, any information you provide to us during an interview, and any assessment information as part of the recruitment process
  • Background information: needed to complete a background check, including references and details of unspent criminal convictions, which will be carried out by us lawfully
  • Other information: CCTV footage, other on-site attendance information obtained through electronic means (such as swipe cards), visitor sign in sheets, and other personal data that is provided by you, or that is required by us to carry out checks

Where we use special categories of personal data (such as racial or ethnic origin, trade union membership, or health data), or criminal record data, we use appropriate measures, including restricted access and security safeguards.

We will only use your personal data where it's reasonable and legal for us to do so.

Appendix 2: reasons for using your personal data

The reasons why we may use your personal data, may include matters related to:

  • Making decisions about your job application and any job offer
  • Checking your right to work in the country*
  • Carrying out background and reference checks, where applicable
  • Our and ODEON Cinemas Group's business admin, management, functioning, planning and safeguarding
  • Operating and managing our IT systems
  • Preventing fraud
  • Equal opportunities monitoring
  • Organising, arranging and managing arrangements for you, or approving expense claims, in connection with the recruitment process
  • Managing disability access and compliance arrangements*
  • Communicating with you about the recruitment process
  • Keeping records related to our recruitment process

Some of these reasons will overlap, and there may be several reasons which allow us to use your personal data. The DPO can provide more details about this.

Generally, we will use your personal data listed above, on the grounds known in legal terms as our 'legitimate interests'. Our legitimate interests are those actions where using your personal data is necessary e.g. to run our business, or for other reasonable purposes to meet the interests of the ODEON Cinemas Group or other individuals, but in any case, only where such use can be reasonably expected by you. (The exceptions are those items above marked: * where the reason is to meet our legal obligations).

We may use special categories of personal data, as mentioned above, or in the following cases:

  • In limited cases, with your express written consent
  • Where we need to carry out our legal obligations
  • For equal opportunities monitoring
  • For legal claims
  • To protect your life (or someone else's) where consent can't be provided
  • Where you have already made the information public (but only where we have a valid need to use it)
  • For employment law purposes, or other purposes permitted by law

We may also use your personal data in the course of our business activities, where we are allowed to do so by law. In every case, we will of course safeguard your personal data.

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