1 The Purpose of this Document

1.1 You are provided with this privacy notice because you are applying for work with Bestway (whether as an employee, worker or contractor). You can find out more here about your privacy rights and how we gather, use and share personal data about you for the purposes of the recruitment exercise, and how long it will usually be retained for, in accordance with the General Data Protection Regulation (EU) 2016/679.

1.2 It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information. We will update this notice if we make any significant changes affecting how we use your personal data, and if so we will contact you to let you know about the change.

2 About us

2.1 When we say 'Bestway' in this notice, we mean other members of the Bestway group of companies, including holding and subsidiary companies, namely: Bestway Group Limited, Bestway (Holdings) Limited, Bestway Securities Limited, Bestway UK Holdco Limited, Bestway Northern Holdings Limited, Oakleaf Limited, Bestway Northern Limited, Bestway Wholesale Limited, Palmbest Limited, MAP Trading Limited and Batleys Properties Limited.

2.2 The company you are applying to work for will be the 'controller' of the personal data you submit in connection with your application and is referred to as 'we', 'us' or 'our' in this notice.

3 Your Privacy Rights

3.1 In addition to the right to be informed about how we use your personal data (as set out in this notice), you have various other rights in respect of the personal data we hold about you – these are set out in more detail below. If you wish to exercise any of these rights, please contact recruitmentdata@bestway.co.uk:

• (a) Right to object: You can object to our processing of your personal data 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 data for direct marketing purposes. Please contact us as noted above, providing details of your objection.
• (b) Access to your personal data: You can request access to a copy of your personal data that we hold, along with information on what personal data we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. Please make all requests for access in writing, and provide us with evidence of your identity.
• (c) Consent: Most of the time, we won't need your consent to use your personal data as we will be using it for the purposes of assessing your suitability for a role with us. However, where you have given us your consent to use personal data, you can withdraw your consent at any time.
• (d) Rectification: You can ask us to change or complete any inaccurate or incomplete personal data held about you.
• (e) Erasure: You can ask us to delete your personal data where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
• (f) Portability: You can ask us to provide you or a third party with some of the personal data that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
• (g) Restriction: You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it.
• (h) No automated decision-making: Please see the section on Automated Decision-Making below.

3.2 Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.

4 What Kinds of Personal Data we Use

4.1 In connection with your application for work with us, we will collect, store, and use the following categories of personal data about you:

• personal contact details such as name, title, addresses, telephone numbers, personal email addresses and Skype ID;
• current salary, bonus and benefits;
• whether you have worked for the Bestway before and whether any of your relatives work for us for the purposes of ensuring there is no conflict of interest in any role that you may be recruited into;
• the information you have provided to us in the application forms, in your CV and covering letter, including in relation to your employment history and qualifications;
• any information you provide to us during an interview;
• information gathered from pre-employment background checks, which may include information about your employment history and qualifications displayed found through publicly available sources, such as LinkedIn;
• references from past employers;
• if you complete any equality monitoring forms, your age and gender;
• copies of right to work documentation; and
• if you have applied for a job as a driver or your role will involve you (and potentially your family members) driving a company car, information obtained through DVLA checks.

4.2 Special protection is given to certain kinds of personal data that are particularly sensitive.

This is information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership ('special categories of personal data') or about your criminal convictions or offences. We will sometimes collect, store and use information about:

• health conditions and disabilities you may have; and
• your criminal convictions and offences, if you submit this information on the application form or in other forms.

4.3 Please see the section on How We Use Sensitive Data and Legal Basis below for further details about how we use this information.

5 How We Gather your Personal Data

We will obtain your personal data in different ways:

• directly from you, for example when you fill out an application;
• from recruitment agencies who you may have signed up to and who have referred you to us, from whom we collect information such as your name, home address, email address, telephone number, NI number and date of birth;
• your named referees, who we may use to verify your employment history; and
• external sources, such as from the DVLA (in the case of roles involving driving).

6 How We Use your Personal Data and Legal Basis

6.1 We have a legitimate interest in ensuring we select the right people to work in our business and process the personal data set out above for the following key purposes in line with those interests:

• to assess your skills, qualifications and suitability for the role with us; and
• to communicate with you about your application and the recruitment process.

We only use your personal data for these purposes to the extent necessary for the purposes of our legitimate interests and will use the data in a way that is consistent with your privacy rights under the law.

6.2 We also use your personal data where required to comply with legal and regulatory requirements – for example, to check you are legally entitled to work in the UK.

6.3 If your application is successful, we will also use your personal data to prepare and enter into a contract with you.

7 How We Use Sensitive Data and Legal Basis

7.1 We process the special categories of personal data set out above and information about your criminal convictions or offences as set out below.

7.2 Reasonable adjustments: we use information about health conditions you may have 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.

7.3 Equal opportunities monitoring: We carry out equal opportunities monitoring, as permitted by law, to ensure meaningful equal opportunity monitoring and reporting. If you complete an optional Equal Opportunities Questionnaire, you may choose to give us information about your age, gender and details of disabilities. Please note, it is not compulsory for you to complete this form, it is anonymous and is used for statistical purposes only.

7.4 Criminal checks: We process the following information about criminal convictions and offences:

• (a) As we are a regulated business and many roles having access to cash or dealing with large volumes of goods which are collectively of high value, we ask in the application form whether you have any relevant unspent criminal convictions (not including parking violations). This helps us to meet our regulatory obligations in respect of money laundering and financial crime and to prevent unlawful acts. It also helps us to determine your suitability for particular roles and helps us to perform our obligations as an employer to provide a safe working environment. However, telling us about a past criminal conviction will not necessarily prevent you from being offered a job.
• (b) If you have applied for a job as a driver, we will also specifically ask about previous driving offences. We need to ask for this information in order to perform our obligations as an employer, as we are expected to check that drivers are competent and capable to drive our vehicles.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. In line with our appropriate policy document, we:

• (a) ensure that criminal convictions information is kept securely, and limited to those who are entitled to see it as part of their duties (for example, HR and hiring managers);
• (b) will only use criminal convictions information for the purposes set out above and for no other purposes; and
• (c) retain the information in accordance with our Data Retention Policy. If you would like further information about our retention periods, please contact recruitmentdata@bestway.co.uk. Generally:

(i) if your application is unsuccessful, we will only record whether the checks yielded a satisfactory or unsatisfactory result, but will not retain the details of the criminal convictions – we will hold this information for six monthly periods in accordance with the section on Data Retention below;

(ii) if your application is successful, we will record whether the checks yielded a satisfactory or unsatisfactory result if this is assessed as relevant to our ongoing employment relationship (but will not retain the details of the criminal convictions). Otherwise, we will delete all of the information.

We rely on you to provide us with accurate information.

8 Automated Decision-Making

8.1 You have the right not to be subject to solely automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law. Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention.

8.2 We do not currently carry out automated decision-making for the purposes of your application, but we will notify you by updating this notice if this changes.

9 If You Fail to Provide Personal Data

If you fail to provide information which we need in order to consider your application when requested (for example, information required to verify your employment history), we will not be able to process your application successfully.

10 Sharing your Personal Data With Others

10.1 We will share your personal data with third parties where required by law, or where it is necessary to process your application with you or where we have a legitimate interest. We will only share your personal data to the extent needed for those purposes.

10.2 We share personal data for these purposes:

• with recruitment agencies who you may have signed up to and who have referred you to us;
• between Bestway group companies, for the internal and administration purposes;
• with external providers, such as The Access Group, who provide and host our resourcing systems; and
• IDS for DVLA checks if you have applied for a driver role or the role will involve you (and potentially your family members driving a company car).

11 Data Retention

11.1 We will never retain your personal data for any longer than is necessary for the purposes for which we need to use it, including for the purposes of satisfying any legal, accounting or reporting requirements.

11.2 You can log in and delete your online account at any point. If after six months there has been no activity then the system will send you an automated email to ask you whether you wish to remain in the database:

• if you do, then we will keep your records for a further six months;
• if you respond to say that you do not, then your account will be deleted;
• if you do not respond then a further email will sent after three more months to advise that your account is to be shut down and all of your personal data will be deleted from our records.

11.3 We retain your personal information for the initial period of six months 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.

11.4 If your application is successful and you become an employee, we will use and hold your personal data as set out in our Staff Privacy Notice.

12 Transfers Outside the UK

12.1 We may need to transfer your personal data outside the UK to other service providers, agents, subcontractors and regulatory authorities in countries where data protection laws may not provide the same level of protection as those in the UK.

12.2 We will take all steps reasonably necessary to ensure that your personal data is handled securely and in accordance with this Recruitment Privacy Notice and the data protection legislation. These include entering into a European Commission approved contract where the country does not provide an adequate level of protection. Some US providers may also be certified under the EU-US Privacy Shield which confirms they have appropriate measures in place to ensure the protection of your personal data. If you would like further information, please contact recruitmentdata@bestway.co.uk.

13 Right to Complain

You can make a complaint to us by contacting us via recruitmentdata@bestway.co.uk or to the data protection supervisory authority – in the UK, this is the Information Commissioner's Office, at https://ico.org.uk/.