Introduction and General Terms
a) This Privacy Notice sets out how Grosvenor Estate Management Ltd (“GEML”), Grosvenor Continental Europe SAS ("GCESAS"), Grosvenor Fund Management Spain SL ("GFMSSL"), Grosvenor Fund Management CE S.A. ("GFMCESA"), Grosvenor FM Sweden AB ("GFMSAB"), obtain, use and protect your personal information that you provide to us, or that is otherwise obtained or generated by us, in connection with an application for a job with us. For the purpose of this Privacy Notice (unless expressly stated, or the context requires, otherwise), ‘we’, ‘us’ and ‘our’ refers to each of GEML, GCESAS, GFMSSL, GFMCESA and ‘you’ refers to you the job applicant.
b) This Privacy Notice explains the following:
- what personal information we may collect from you;
- how we keep your personal information safe;
- what we may use your personal information for;
- who we may share your personal information with; and
- your rights regarding your personal information.
c) GEML, GCESAS, GFMSSL, GFMCESA and GFMSAB are each a data controller in respect of your personal information for the purposes of applicable data protection legislation.
Legal ground for processing personal information
We will process personal information relating to you on the ground that such processing is necessary to further our legitimate interest in the effective consideration and handling of your job application (“Application”) and the efficient and effective administration of our businesses. We may also process your personal information to the extent necessary to comply with our legal obligations.
Personal information we may process about you
a) How do we collect personal information about you?
We collect personal information from the Application that you, or a recruitment agent on your behalf, submit to us. You do not have to provide the personal information we request from you as part of your Application, but it may result in a delay in us processing your Application (or us not being able to process your Application at all) if that personal information is not provided.
b) What types of personal information may we process about you?
As part of your Application you may provide us with your name, email address, postal address, telephone, mobile numbers, salary, work history and/or CV details, as well as the name, telephone, mobile numbers and/or email address of any referee(s) (which we will only use for the purpose of obtaining a reference). You may also provide us with personal information when you respond to questions we may ask as part of the wider job application process (for instance as part of any test you carry out prior to or during any interview you attend).
Keeping your personal information safe
a) Where the personal information is held
We store your personal information on the recruitment software system, i-Grasp, which is provided and hosted by a third party, Lumesse. This is a secure system that complies with industry standards and protects your personal information from unauthorised access. Access to the i-Grasp system is limited to members of the HR recruitment team and the hiring manager(s) relevant to your Application (see section 6).
Your personal information is also retained on electronic and paper files. The electronic files are encrypted and all paper files, when disposed of, are put in the confidential waste. Access to such files is limited to the HR recruitment team and its supporting team for the job application process (see section 6).
b) Retention of your personal information
The length of time that we hold your personal information on our systems will depend on the status of your Application, as follows:
- if you do not access your details on the application website for more than one year, your personal information is deleted and can no longer be searched for;
- if your Application is unsuccessful, one year (two years in the case of Sweden) following the date on which we notify you that your Application has been unsuccessful;
- if your Application is successful but you do not accept the role, one year (two years in Sweden) following the date on which you decline the job offer; or
- if your Application is successful and accept the role, six years following the date on which your contract with us terminates.
We may also hold your personal information on our systems for longer than these stated periods if required to do so by law. Please note, the duration for which we retain your personal information may vary depending on where you are located but, in all cases, your personal information will not be retained for longer than is necessary for the purposes of the data processing.
Note that our processing of your personal information may continue after your job application process has come to an end.
What we may process your personal information for
We process your personal information for the following purposes:
- to screen your Application and assess your suitability for the role you have applied for;
- to send you an invite to an interview;
- to request that you perform a test in connection with your assessment for the role that you have applied for;
- for recording internal notes about your interview;
- to notify you about the outcome of your interview;
- to notify you about alternative roles that we believe you may be suitable for;
- if your Application is successful and we offer you the role, to prepare you for our job induction process;
- complying with any applicable present or future law, rule, regulation, guidance or directive, and complying with any applicable industry or professional rules and regulations or any applicable voluntary codes;
- complying with demands or requests made by local and foreign regulators, governments and law enforcement authorities, and complying with any subpoena or court process, or in connection with any litigation; and
- activities connected with any sale, merger, acquisition, disposal, recognition or similar change of our business.
Who we may share your personal information with
a) We may share your personal information with any of the following recipients as may be necessary or desirable for the purposes described in section 5:
- our HR recruitment teams;
- our hiring manager(s) for the role that you have applied for;
- the interview panel for the role you have applied for;
- third party service providers that assist us with the screening of job applications;
- third party service providers that will host job applications on our behalf;
- local and foreign regulators, governments and law enforcement authorities;
- local and foreign courts, tribunals and arbitrators, other judicial committees and enactments of laws; and
- persons connected with any sale, merger, acquisition, disposal, reorganisation or similar change to our business (including any potential or actual purchaser or that business and that purchaser’s advisors).
b) All third parties to whom we transfer personal information relating to you will be under an obligation to protect the confidentiality and security of that personal information.
c) In connection with our business and for employment, administrative, management and legal purposes, we may transfer your personal data outside the EEA to our group in North America (via Grosvenor Americas) and in Asia (via Grosvenor Asia). We will ensure that the transfer is lawful and that there are appropriate security arrangements and we will notify you and provide details of the subject matter, destination and purpose of any such transfer of your personal data outside the EEA.
d) Although there is no decision by the European Commission that the US and Asia provides an adequate level of protection, we have entered into an agreement ensuring appropriate and suitable safeguards with our group members the US and Asia. This is in standard terms adopted by the Information Commissioner and approved by the Commission. If you wish to see details of these safeguards, please contact us using the details in section 10.
Your rights regarding the personal information you provide to us
The accuracy of the personal information we hold about you is important to us. Under applicable data protection legislation you have rights concerning your personal information.
- You have a right to correct any inaccurate or incomplete personal information we hold on you. You have a right to receive a copy of the personal information we hold on you, which we must provide to you in a structured, commonly-used and machine-readable format. You have a right to require us to stop or to restrict our processing of your personal information. You have a right to require the erasure of personal information we hold on you once it is no longer necessary in relation to the purposes for which the personal information was collected or is being processed.
- You have a right to establish guidelines for the conservation, the deletion and the communication of your personal information after your death (only applicable if you are based in France).
- Please contact us if you wish to exercise any of these rights using the details in section 10.
- If you have a complaint about how we manage your personal information please contact us. Our contact details are in section 10.
- If you wish to pursue a complaint further once the internal complaints process is complete you have the right to contact the organisation for the jurisdiction in which you are based.
- Please see the details for each country below.
- France: Contact the Commission Nationale de l'Informatique et des Libertés (CNIL) and click on this link to be redirected to their website.
- Italy: Contact the Garante per la protezione dei dati personali and click on this link to be redirected to their website.
- Luxembourg: Contact the Commission Nationale pour la Protection des Données and click on this link to be redirected to their website.
- Spain: Contact the Agencia de Protección de Datos and click on this link to be redirected to their website.
- Sweden: Contact the Datainspektionen and click on this link to be redirected to their website.
Changes to this Privacy Notice
We will review and may update our Privacy Notice from time to time. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on our website. Please check our website frequently to see any updates or changes to our Privacy Notice, a summary of which we will set out in section 9 below. In any event, all important changes made to our Privacy Notice will be notified to you by email or post.
This Privacy Notice was last reviewed and updated in April 2018.
Previous changes to this Privacy Notice
If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please do not hesitate to contact us at:
By post: Human Resources Recruitment, The Grosvenor Office, 70 Grosvenor Street, London, W1K 3JP
By email: email@example.com
By phone: 0207 312 6334.