HotelREZ Hotels & Resorts Recruitment Privacy Policy
What is the purpose of this document?
HotelREZ Limited is a “controller” in relation to personal data. This means that 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 a role or position 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 UK General Data Protection Regulation (UK GDPR) or, where applicable, the General Data Protection Regulation ((EU) 2016/679) (GDPR).
Data protection principles
We 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.
Who is your personal information collected from?
We collect personal information about candidates from the following sources:
• Recruitment agencies through which candidates apply, from which we collect the following categories of data: your curriculum vitae, a covering letter and any data gathered from initial screening tests that the recruitment agency may carry out.
• Your passport or current visa papers which indicate your right to work legally in the country where the role is being offered.
• Your named referees, from whom we request information about your previous employment dates, position and performance.
• Agencies which carry out (or facilitate) credit and/or financial checks.
• Disclosure and Barring Service (and similar overseas agencies) in respect of criminal convictions.
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 including your name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications and any other information supplied.
• Any information you provide to us during an interview.
• The results of aptitude tests that may be carried out as part of your application process.
• Information obtained from sources other than yourself previously referred to in this notice.
• Information about your right to work in the country where the role is being offered and your visa status.
Where the role you have applied for is regarded by us as necessitating additional or enhanced checks (which will normally be roles having access to financial and/or credit card information, or otherwise involving a high degree of trust and integrity), this may involve us collecting, storing and using the following types of more sensitive personal information:
• Information about criminal convictions and offences.
• Information relating to your credit and financial status.
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 you have applied for.
• 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.
We need information regarding your right to work in the relevant country to comply with our legal obligations.
It is in our legitimate interests to decide whether to appoint you to the role you are applying for since it would be beneficial to our business to appoint an appropriate person to that role.
We need information regarding criminal convictions and enhanced credit and financial checks to ensure that we comply with our legal obligations and it is in our legitimate interests to ensure that the persons appointed to sensitive roles or positions have been subjected to appropriate screening.
We need to process your personal information to decide whether to enter into a contract with you.
Having received your CV and covering letter 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 will then take up references, carry out checks about your right to work in the country where the role is based and, where appropriate, carry out credit, financial and criminal record checks (which we call Enhanced Screening), before confirming your appointment. We will not carry out Enhanced Screening without your consent. Enhanced Screening will be carried out in accordance with our Employee Screening Policy.
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. For example, if we require a criminal records 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.
Information about criminal convictions
If the role you have applied for requires Enhanced Screening, we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer you a role which requires a high degree of trust and integrity (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.
We have in place an appropriate policy document and safeguards, which we are required by law to maintain when processing such data.
Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
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: recruitment agencies, and (where Enhanced Screening is undertaken) credit, financial and criminal record screening agencies and service providers. All our third-party service providers 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 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. Details of these measures may be obtained from our data privacy manager at privacy@hotelrez.com.
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.
Data retention
How long will you use my information for?
We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to appoint you to the role you have applied for. 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 and applicable laws and regulations.
If we would like to retain your personal information on file, on the basis that we might be able to consider you for an opportunity that may arise in future, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period for that purpose.
Rights of access, rectification, erasure, objection, restriction and data portability
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 making 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 rectification 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 contact our data protection manager in writing at (privacy@hotelrez.com).
Questions or complaints
If you have any questions or concerns about this privacy notice or how we handle your personal information, please contact our data privacy manager who has been appointed to oversee compliance with this privacy notice at privacy@hotelrez.com.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) who is responsible for data protection issues in the UK and whose contact details are available on its website. If you are based outside the UK, you may also have the right to make a complaint to the relevant local data protection authority.