Fortune Media Group (UK) Limited – Job Applicant Privacy Notice
Last Revised: January 26, 2023
Introduction
As part of any recruitment process, Fortune Media Group (UK) Limited, which includes its affiliates, (Fortune, we, us, our) collects and processes personal data relating to job applicants. This Privacy Notice sets out the categories of your personal data we collect, how we collect it, what we use it for and with whom we share it.
By personal data we mean any information relating to you such as your name or contact details. Personal data does not include data which has been anonymised, such as data from equal opportunities monitoring carried out on an anonymised basis.
Fortune is a data controller. This means that we are responsible for deciding how we hold and use personal data about you. Should you have any questions about this Privacy Notice you can contact us at privacy@fortune.com.
What information do we collect about you and what do we use it for?
The types of personal data about you which we may collect, store and use are set out in the table below and in each case we have specified the purpose and our ‘lawful basis’ for processing it. The law specifies certain ‘lawful bases’ for which we are allowed to use your personal data. Most commonly, we will rely on one or more of the following lawful bases for processing your personal data:
- where it is necessary for compliance with a legal obligation to which we are subject; and/or
- where it is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms, which require protection of your personal data.
Where Fortune relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of job applicants and has concluded that they are not.
| Category of personal data | Examples | Purpose | Lawful basis for processing | Legitimate interest (where applicable) |
| Contact details | Name, address, email address and telephone number, and photograph if provided | For administration purposes during the recruitment process | Legitimate interests | To make contact with job applicants during recruitment process |
| Application related documents provided by candidates | Application form, CV and cover letter, and photograph if provided | To assess job applicants and shortlist for interview | Legitimate interests | To make recruitment decisions and maintain standards of integrity and excellence in Fortune’s workforce |
| Application documents generated by Fortune | Feedback and notes from interviews or other selection processes | To assess the job applicant’s application and make recruitment decisions | Legitimate interests | To make and justify recruitment decisions and maintain standards of integrity and excellence in our workforce |
| Details about current remuneration | Current level of salary and benefit entitlements | To make decisions about the financial package for offer | Legitimate interests | To ensure appropriate and attractive financial packages are offered to job applicants. |
Special categories of personal data
Some personal data is more sensitive and requires a higher level of protection. This is personal data which reveals or contains:
- racial or ethnic origin
- political opinions
- religious and philosophical beliefs
- trade union membership
- genetic data
- biometric data
- health data
- sex life or sexual orientation
We will process special category personal data because we have a lawful basis for doing so and primarily because it is necessary:
- for the purposes of carrying out our obligations and exercising specific rights in the field of employment law (employment law obligations); and/or
- for the assessment of your working capacity.
However, in limited circumstances we may be required to process special category data from job applicants to respond to and defend legal claims.
The special categories of data about you which we may collect, store and use are set out in the table below and in each case we have specified the purpose and our ‘lawful basis’ for processing it.
| Category of special categories of personal data | Examples | Purpose | Lawful basis for processing |
| Medical/health information provided as part of application process | Details relating to any disability | To make reasonable adjustments to the recruitment process | Compliance with legal obligations and employment law obligations |
| Immigration information | Passport, driver’s license, visa, work permit | To check your right to work in the relevant jurisdiction for which you are applying | Compliance with legal obligations and employment law obligations |
| Information for equal opportunities monitoring | Race/ethnicity, sexual orientation, religion/philosophical belief & disability | To allow us to monitor equal opportunities | Compliance with legal obligations and employment law obligations |
We do not require you to provide any special categories of personal data other than those outlined in the table above. We recommend that you do not include any additional special categories of personal data in your application as it is unlikely to be relevant to the application process.
Information relating to criminal convictions and offences
If and when you have been made an offer of employment, Fortune processes limited information about criminal convictions and offences where this is appropriate given the nature of the role and where we are legally able to do so by conducting criminal convictions checks through a vendor. Generally, this will be to assist Fortune in assessing your fitness and propriety to perform your role as forms part of generally accepted principles of good practice, and to protect against dishonesty and misconduct. Our lawful basis for processing this information is compliance with employment law obligations and/or our legitimate interests and prevention and detection of unlawful acts / regulatory requirements / protection of the public.
What if you do not provide the personal data we request?
You are not under any statutory or contractual obligation to provide data Fortune requests during the recruitment process. However, if you do not provide the information, we may not be able to take your application further. We will notify you if this is the case.
Change of purpose
We will only use your personal data for the purposes for which we collected it (as identified under Purpose above), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
How do we collect this information?
In addition to the data we collect from you during the recruitment process, we may receive personal information about you from third parties, such as:
- recruitment consultants;
- former employers and any other named referees; and
- agencies we engage to conduct background checks.
With whom will we share your information?
Your information will be shared internally including with other entities in our group for the purposes of the recruitment process. This includes members of the HR and recruitment team, interviewers and managers in the business area to which the vacancy relates.
Fortune will not share your data with non-affiliated external third parties, unless your application for employment is successful and Fortune makes you an offer of employment. Fortune will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks. We may share your personal data with third parties, for example with a regulator or otherwise to comply with the law.
We may transfer the personal data we collect about you to the United States, Hong Kong, Macau and the People’s Republic of China for our legitimate interests in evaluating your eligibility for employment. These countries are not deemed to provide an adequate level of protection for your personal information.
We have put in place standard contractual clauses to ensure that your personal data is treated in a manner that is consistent with and respects the EU and UK laws on data protection. If you require further information about this you can request it from privacy@fortune.com.
For how long does Fortune retain data?
If your application for employment is unsuccessful, Fortune will hold your data on file for one year after the end of the relevant recruitment process. At the end of that period, your data will be deleted or securely destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held are explained in our Staff Privacy Notice.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
Your rights in relation to your information
You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:
- request access to your personal data (commonly known as a data subject access request) and request certain information in relation to its processing;
- request rectification of your personal data;
- request the erasure of your personal data;
- request the restriction of processing of your personal data;
- object to the processing of your personal data; and
- request the transfer of your personal data to another party.
If you want to exercise one of these rights please contact us at privacy@fortune.com. You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Fees
You will not usually have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is to ensure that personal data is not disclosed to any person who has no right to receive it.
Further information
This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information, please do not hesitate to contact privacy@fortune.com.