Recruitment Privacy Notice

1. Introduction

1. This Privacy Notice sets out how Grosvenor obtains, uses and protects your personal information when you apply for a job with us. For the purpose of this Privacy Notice, ‘we’, ‘us’ and ‘our’ refers to the recruiting Grosvenor company (which are listed in the Annex) and ‘you’ refers to you (the job applicant).
     
2. This Privacy Notice explains the following:
   1. what personal information we may collect from you;
   2. how we store your personal information;
   3. what we may use your personal information for;
   4. who we may share your personal information with; and
   5. your rights regarding your personal information.

2. Personal information we may process about you

1. 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 any to process your Application at all) if that personal information is not provided.

 If accessing our recruitment site, our recruitment software provider may also set cookies on your device and capture certain device/network information (such as IP address) which our provider believes are necessary for its operation and for which our provider is solely responsible.

2. What types of personal information may we process about you?

As part of your Application you may provide us with your name, gender, email address, postal address, telephone, mobile numbers, work history, references, professional and education history, remuneration details, 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). This may include interview feedback, passport or identify information and performance on recruitment assessment tests.

We may also collect information as part of the recruitment process from third party background screening companies, where this is considered necessary for the role. 

Additionally, and with your consent, we may instruct a Disclosure and Barring Service (DBS) check (or equivalent in non-UK jurisdictions, depending on the country relevant to your job application), where this is considered necessary for the role for which you have applied. This will provide us with details of criminal convictions and cautions from national police records that are considered to be unspent. This is “special category data” and will be treated accordingly.

3. Storing your personal information

1. Where the personal information is held

We store personal information relating to your job application on our recruitment software system (if you are using it) and in our electronic and paper files. Direct access to this information is limited members of the HR recruitment team, the hiring manager(s) relevant to your application and their respective supporting teams. However, see also section 5 for information on how we share your personal information.

2. Retention of your personal information

The length of time that we hold your personal information on our systems is detailed below.

1. If you applied via our recruitment software system (Workday): One year after either: (a) the date your Workday account was created or (b) the date that you last signed into your Workday account, whichever is the later.

2. If you applied via email: One year after the date of your application.

3. If your job application is successful and you accept the role, your recruitment information may be included as part of company records relating to your employment and retained in accordance with our employee privacy notices and policies.

4. We may hold your personal information on our systems for longer than these stated periods if you agree that we may retain your details to contact you about future job opportunities at Grosvenor or if required to do so by law.

Special category data (e.g. data gleaned from DBS checks relating to criminal convictions and cautions) will not be stored or retained on our systems.

4. Why we process your personal information

We process your personal information for the following purposes:

• to screen your job 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, where you have given us permission to do so; 
• if your job application is successful and we offer you the role, to prepare you for our job induction process;
• to inform us in making safe recruitment decisions; 
• 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.

5. How we share your personal information

1. We may share your personal information with any of the following recipients as may be necessary for the purposes described in section 4:
   • 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;
   • other persons supporting employment, administrative, management and legal matters in Grosvenor companies in the UK, Europe, Asia and/or America;
   • third party recruitment agencies managing your application;
   • third party service providers that assist us with the screening of job applications;
   • third party service providers that provide our recruitment systems and host information relating to job applications on our behalf;
   • third parties that provide us with advice or professional services, including insurers, auditors, lawyers, accountants and tax advisors;
   • local and foreign regulators, governments and law enforcement authorities;
   • local and foreign courts, tribunals and arbitrators, other judicial committees and enactments of laws; and
   • actual purchaser or that business and that purchaser’s advisors).
2. In connection to the transfers referred to in paragraph 1 above, we may transfer your personal data outside of your country of residence. We will ensure that the transfer is lawful and that there are appropriate safeguards in place to the extent required by law (where applicable, additional regional information is set out in the Annex).
   
   
3. All third parties to whom we transfer personal information relating to you, or whom we instruct to process personal information relating to you on our behalf, will be under an obligation to protect the confidentiality and security of that personal information. 

6. Your rights regarding the personal information you provide to us

Depending on the job you are applying for and your location, you may have rights concerning your personal information under applicable data protection and privacy laws. These may include:

• A right to receive information about our processing of your personal information, such as what is collected, where it is obtained from, what it is used for, whether it is disclosed and to whom.
• A right to receive a copy of the personal information we hold on you in a structured, commonly-used and machine-readable format.
• A right to correct inaccurate or incomplete personal information we hold on you.
• A right to require us to stop or to restrict our processing (including transfer to third parties) of your personal information (particularly where unlawfully used or obtained).
• 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.

If you wish to exercise any of these rights, or if you have a complaint about how we manage your personal information, please contact us using the details below. If you are not satisfied with our response, please note that you may also be able to complain to your local government agency which regulates the protection of personal information (see the Annex).

7. Contact

If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please do not hesitate to contact the recruiting Grosvenor company using the details in the Annex or email data.protection@grosvenor.com.                                                                                                                                              

Annex

Part 1 – Recruiting Grosvenor Companies / Data Controllers

Grosvenor Family Office and Rural Estates

1. The 4th Duke of Westminster's 1964 Settlement Trust of Eaton Estate Office, Eccleston, Chester CH4 9ET

Grosvenor Property

• Grosvenor Diversified Property Investments:
  • Grosvenor Estate Management Ltd
  • Grosvenor Group Management Services Limited 
  • Realty Insurances Ltd.
     (each of 70 Grosvenor Street London W1K 3JP)
• Grosvenor  Property UK:
  • Grosvenor Estate Management Ltd.
  • Grosvenor Property Management Services Ltd.
  • Grosvenor Estates Belgravia
  • (each of 70 Grosvenor Street London W1K 3JP)
• Grosvenor Property Asia:
  • Grosvenor Asia Pacific Limited, 5/F Manulife Place, 348 Kwun Tong Road, Kowloon, Hong Kong
• Grosvenor Property Americas:
  • Grosvenor USA, 1 California Street, Suite 2500, San Francisco CA 94111, USA
  • Grosvenor Canada Limited, 1040 W. Georgia Street, #2000, Vancouver BC V6E 4H1, Canada
• Grosvenor Food and AgTech:
  • 
    
    • Grosvenor Food & AgTech Limited, 70 Grosvenor Street, London, W1K 3JP
    • Grosvenor Food & AgTech US Inc, 3000 El Camino Real, Building 4, Suite 200, Palo Alto, 94306, USA

Part 2 – Regional Specific Information

1. UK 

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 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.

Where personal information is transferred outside of the UK for the purposes explained in this privacy notice, we will ensure that the recipient is subject to standard contractual clauses approved by the Information Commissioner's Office or such other safeguards as permitted by the UK Data Protection Act 2018 or the General Data Protection Regulation. If you wish to see details of these safeguards, please contact us using the details in section 7.

2. Californian Residents

If you are a California resident, in addition to some of the rights referred to in Section 6, under the California Consumer Privacy Act (CCPA) you may also have the following rights:

• the right to “opt out” of the sale of your personal information to a third party.
• the right to receive equal service and pricing even if you exercise your rights under the CCPA.

The personal information that is collected, and its sources and uses, is more fully described in the body of this notice above. We do not sell your personal information to third parties.

Part 3 - Regulators

In the event that you wish to make a complaint as referred to in section 6, the following organisations may be of assistance depending on the jurisdiction:

• UK: Information Commissioner’s Office (https://ico.org.uk/)
• Hong Kong: Privacy Commissioner for Personal Data (link).
• Canada: Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca/en/)
• California: Office of the Attorney General, California Department of Justice (https://oag.ca.gov/privacy)