Recruitment Privacy Notice
GLOBAL CAREERS
Thank you for visiting the Imperial Brands Global Careers website (Website) and for your interest in Imperial’s career opportunities.
Information this Privacy Notice covers:
· How we collect personal information
· Additional information collected if your application is successful
· Purposes and legal basis that permits us to use your personal information
· If you do not provide the personal information that we request
· Who we share your personal information with
· How and where we store your information
· How long we keep your information for
We are Imperial Tobacco Limited, 121 Winterstoke Road, Bristol, BS3 2LL in the United Kingdom (Imperial, we, our, or us). Imperial is the data controller which means we are responsible for deciding how we hold and use your personal information. We are responsible for operating these online career services for the Imperial Brands group of companies.
This Privacy Notice applies to all applicants applying for global positions with Imperial Brands’ companies on our Website and explains what personal information we collect about you online and offline in our recruitment process, and how we use and share that information.
We encourage you to review our Privacy Notice carefully before applying for any of our jobs. If you have any questions about how we handle or protect your personal information, please contact us using the contact details below.
In addition to the commitments set out in this Privacy Notice, Imperial Brands has a set of data privacy rules which apply to the processing of all personal information by our organisation. These privacy rules can be found at:
https://www.imperialbrandsplc.com/healthier-futures/governance/policies
How we collect personal information
We collect information from you when you register your user profile and apply for a job with us. We collect some information about you automatically, such as information collected by cookies, when you use, access, or interact with us via our Website. Some of the information we collect about you comes from third-parties such as recruiters, analytics service providers or, depending on your “settings”, social media providers.
We collect, store and use personal information that you provide during our drive to recruit skilled and talented people to join our teams.
“Personal information” is any information that can identify you. Some personal information is classified as "special category personal information" under data protection legislation. This includes information relating to health, racial or ethnic origin, religious or philosophical beliefs, political opinions, genetic and biometric data, sex life, sexual orientation, and trade union membership. This personal information is more sensitive and we need to have further justifications for collecting, storing and using it. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.
We collect the following kinds of personal information about you as part of the recruitment and pre-employment checking processes:
o name (including title);
o contact details (address, email, phone numbers);
o date of birth;
o nationality/citizenship;
o identification documents;
o employment history;
o education;
o information from your CV;
o information generated as part of the recruitment process, such as interview notes, right to work documentation, qualifications, and references; and
o IP address, location data and other information generated by your use of our Website.
We ask you to let us know about any disability for which you need us to make reasonable adjustments during the recruitment process, and provide your consent to us processing this information for this purpose. We will ask you for your consent for us to process certain demographic information about you, which may include special category personal information in order to monitor diversity and equality of opportunities in our internal HR records. We may also ask you if you are happy for us to use this information on an anonymous basis as part of our ongoing efforts to ensure our recruitment processes are inclusive.
Using LinkedIn
You can choose to use your LinkedIn profile on our Website. If you do, you will be asked to allow Imperial access to your profile information. This includes the telephone number and email address associated with your LinkedIn account as well as your experience, education, skills and recommendations. Please note that this is a once only import and you will need to ensure the ongoing accuracy of your personal information in your Imperial user profile. During any subsequent application you will have the opportunity to update your information using your LinkedIn profile again. You can disconnect your LinkedIn account from the Website at any time from your “settings” in LinkedIn.
Additional information collected if your application is successful
Should you be successful in your application, and where the laws in your country allow it, we will conduct background checks using a third-party service-provider. Depending on the role that you’ve applied for, background checks will be required and can involve searches against criminal records, court records and checks related to credit-worthiness or credit standing. The service-provider we use varies according to your location. You will be asked to complete a “Declaration of Consent” which explains what information is collected.
At this stage, we will also contact the references you provide to us from your previous employers.
We will use the information gathered from the background checks and from references to decide whether or not to make an offer of employment.
What are the purposes and legal basis that permits us to use your personal information?
The list below provides more detail about the personal information we use and the legal basis that we rely on in each case:
o Purpose: Recruitment decisions including
o Finding appropriate candidates to fill our job openings;
o Considering your application for the role that you have applied for and other roles available which you may not have applied for; and
o Carrying out relevant pre-employment checks and screening.
Personal information collected
Name and title, contact details, recruitment information (such as CV, information provided in a cover letter, references), employment records, information generated as part of the recruitment process, identification documents, IP address, location date and other information generated by your use of our Website, and information about criminal convictions and offences committed by you.
Lawful basis
Performance of contract and legitimate interests, to evaluate whether you have the necessary skills and qualities to perform the relevant role.
o Purpose: Contact you about potential roles and the recruitment process
Personal information used: Contact details, web pages you view, recruitment information (such as CV, information provided in a cover letter, references), employment records.
Lawful basis
We rely on your consent to contact you about roles that you have not applied for, and about any further recruitment opportunities.
o Purpose: Right to work
Personal information collected
Information relating to your right to work status, identification information depending on which country your role is in (for example, in the UK, national insurance number), passport number, nationality, tax status information and contact details.
Lawful basis
Performance of contract, compliance with laws, and legitimate interests, to ensure that those who work for us have the right to work in their relevant location.
o Purpose: Fraud and crime prevention
Personal information collected
Identify verification information.
Lawful basis
Compliance with laws, public interest, and legitimate interest, to ensure the prevention of fraud.
o Purpose: Diversity monitoring
Personal information collected
Gender, marital status and dependents, and information about your race or ethnicity, religious beliefs, health, and sexual orientation.
Lawful basis
With your consent, to assess diversity of candidates and employees and to offer equal opportunities to all.
o Purpose: Providing reasonable adjustments
Personal information collected
Health information.
Lawful basis
With your consent.
o Purpose: Legal disputes
Personal information collected
Contact details, information from your CV and submitted as part of the selection process and interview notes.
Lawful basis
Legitimate interests. It is in our legitimate interest to process personal information to make and defend against legal claims.
o Purpose: Data analytics
Personal information collected
Device IP address, web pages you view and whether you interact with the content on the site, list of active devices, associated IP addresses, contents of forms submitted, files containing CVs.
Lawful basis
Legitimate interests. It is in our legitimate interest to evaluate our Website and its services to ensure its effectiveness. Where possible, we use this data in aggregated, non-identifiable form. Otherwise, we get consent.
What happens if you do not provide the personal information that we request?
We need certain personal information in order to conduct the recruitment and selection process or to alert you to job recommendations as part of our candidate relationship management service. If you do not provide certain personal information, we may not be able to continue with the recruitment process and offer you employment/engagement, or we may not be able to alert you to jobs that might be of interest.
Who we share your personal information with
As part of the process, we share the personal information supporting your application with the relevant Imperial Brands department or function that advertised the role, and other Imperial Brands departments with potentially suitable vacancies.
We share your information with the following categories of third parties:
As part of the process, we share the personal information supporting your application with the relevant Imperial Brands department or function that advertised the role, and other Imperial Brands departments with potentially suitable vacancies.
We share your information with the following categories of third parties:
o suppliers of our recruitment software to manage recruitment campaigns, including Cielo Talent and Lumesse;
o third-party testing and screening providers for the purpose of carrying out evaluation and testing of your suitability for a job;
o trusted partners or other organisations we are running recruitment campaigns on behalf of for the purposes of secondments, placements, and joint working ventures. Where this is the case, the job description will specify who those parties are;
o any third parties whom we have engaged to carry out a recruitment process on our behalf, such as recruiters, with whom we share shortlisting or interview feedback;
o service providers, such as building facilities, health and safety or catering staff to ensure appropriate arrangements are in place for you to visit our premises;
o regulators and government agencies, such as HMRC for the purposes of making returns and fulfilling our reporting obligations;
o other third parties, such as the police or similar organisations, where necessary for the prevention and detection of crime or where there is a legal requirement to do so;
o contractors and designated agents where required to process your application;
o professional advisors and corporate auditors; and
o any other third parties that you consent to.
How and where we store your information
Imperial is a global organisation and our vacancies arise all over the world. We will pass your information to the part of the organisation with the job vacancy you have applied for where it will be used to consider your application. In some cases, this will be outside of the UK or the European Economic Area (EEA).
Any personal information you submit via the Website will be transmitted to Imperial’s global recruitment system and shared with Imperial’s global recruitment services providers.
If we or our suppliers transfer your personal information to a different country we will take steps to ensure that such transfers comply with applicable laws. If you would like more information on the specific mechanisms used by us when transferring your personal information out of the UK or EEA, please contact us using the details below.
Transfers of personal information originating in the UK or EEA within the Imperial Brands group are governed by internal data processing agreements.
How long we keep your information for
We will keep your user profile and any application data for as long as legally required in a particular country. However, if your application is successful and you are hired by an Imperial Brands company, your personal information collected during the recruitment process will be used to form the basis of your employment record and retained for the duration of your employment.
When your information is no longer needed in our recruitment systems (for example, because you are no longer maintaining your user profile), unless there is a legal reason to keep it, your information will be kept for a maximum of 12 months from the date the record was last modified, when it will be irretrievably anonymised. If you wish to make an application for a role at Imperial after this time, you will need to set up a new user profile.
There will be some circumstances where we have statutory obligations to keep your personal information for a longer period or where it is necessary in case of a legal claim. If this is the case, you will be informed accordingly.
You can access and change/delete your user profile content at any time and may also request that your entire user profile be deleted from our database. Your “My Settings” page also gives you the chance to anonymise yourself.
Your information rights
You have the right, within certain legal parameters, to:
o be informed about how and why we use your personal information;
o obtain access to your personal information that we hold;
o request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate (or you can update it yourself in “My Settings”);
o ask us to erase our records of your personal information in certain circumstances;
o ask us to restrict our information processing activities in certain circumstances;
o ask us for a copy of your personal information that you have provided to us in a commonly used machine readable format;
o object to our processing of your personal information; and
o not be subject to automated decisions about you and to request human intervention.
For more information or to exercise your rights, please contact us using the details below.
Cookies Policy
This Website uses cookies. For more information, please see our Cookies Policy.
Contact us
Support: If you need any help with our careers services, please contact our recruitment team at resourcing@uk.imptob.com.
Privacy: If you have any questions, concerns or complaints relating to the handling of your personal information and your privacy, please email data.protection@uk.imptob.com.
Lodging a complaint
If we cannot resolve your complaint, you have the right to complain to the UK’s Information Commissioner’s Office at https://ico.org.uk or your local Data Protection authority. If you are within the EEA, a list of equivalent European Data Protection Regulators can be found here.
Changes to this Privacy Notice
We will keep this Privacy Notice updated and, if you have a user profile, keep you informed of any material changes to the way we process your personal information. We encourage you to read about the changes so that you keep up to date.
This Privacy Notice was last updated on 23 July 2024.
Version 1.0
Date: August 2019
Detail: First published
Version 1.1
Date: January 2022
Detail: Inclusion of version history table
Update of systems used to process personal information
Update cross-border transfer section
Version 1.2
Date: January 2024
Detail: Updated personal information collected list
Updated Code of Conduct link
Updated Cross Border Transfers paragraph
Added European Data Protection Regulators link
Version 1.3
Date: July 2024
Detail: Updated purpose and lawful basis for processing data during recruitment and how it is presented
Other general updates