BACKGROUND AND PURPOSE
Maybourne Hotels Limited (company no: 3669284) manages Claridge's, The Connaught, The Berkeley, The Maybourne Beverly Hills and The Maybourne Riviera – five of the most renowned hotels in the world, which altogether trade under the name of Maybourne Hotel Group.
Our hotels have histories that stretch back over a century. And, while each one retains its timeless appeal and individual nature, we are committed to ensuring they are always in tune with the wants and wishes of today’s discerning guests.
This Privacy Notice covers how we collect, use, store and disclose the data that you supply to us and your rights to access, amend and remove data that we hold about you. We are committed to protecting the privacy and security of your personal information and we will always treat you and your data with the respect you deserve.
THE INFORMATION WE COLLECT FROM YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We will collect, store, and use the following categories of personal information about you:
1. [Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.]
2. [Date of birth.]
4. [Marital status and dependants.]
5. [National Insurance number.]
6. [Salary, annual leave, pension and benefits information.]
7. [Start date.]
8. [Location of employment or workplace.]
9. [Copy of driving licence.]
10. [Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).]
11. [Employment records (including job titles, work history, working hours, training records and professional memberships).]
There are “special categories” of more sensitive personal data which require a higher level of protection. We may also collect, store and use the following “special categories” of more sensitive personal information:
12. Information about your health, including any medical condition, health and sickness records (including Occupational Health records).
13. [Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.]
14. [Information about criminal convictions and offences.]
How the information is collected
We collect personal information about potential employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies such as the Criminal Records Bureau and the Driver Vehicle Licensing Association. If successful, we may collect additional personal information in the course of job-related activities throughout the period of you working for us.
When we will use your personal information
We need all the categories of information identified above primarily to allow us to to comply with legal obligations[**] and in the majority of cases we may use your personal information to pursue legitimate interests of our own or those of third parties[***] (provided your interests and fundamental rights do not override those interests). The situations in which we will process your personal information are identified below. We have indicated by [asterisks] the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved within the table below.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
|Purpose||Type of data||Lawful Basis|
|[Making a decision about your recruitment or appointment.]||1, 4, 14||***|
|[Determining the terms on which you work for us.]||6, 7, 8, 10, 11||***|
|[Checking you are legally entitled to work in the UK.]||1, 2, 5, 9||**|
|[Equal opportunities monitoring.]||1, 2, 3, 4, 12, 13|| ***
Failure to provide information
If you fail to provide certain information when requested, we may not be able to make a decision as to your suitability for the role for which you have applied.
SENSITIVE PERSONAL INFORMATION
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations and in line with our data protection policy.
3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our workplace pension scheme, and in line with our data protection policy.
4. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.
Our obligations as a prospective employer
We will use your particularly sensitive personal information in the following ways:
- We will use information about your physical or mental health, or disability status, to assess your fitness to work and to provide appropriate workplace adjustments.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.
Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We may also process such information about members or former members in the course of legitimate business activities with the appropriate safeguards.
We may have to share your data with third parties, including third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services.
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
When might you share my personal information with other entities in the group?
We will share your personal information with other entities in our group [as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
If you are not offered an interview for a role then we will destroy your personal data after 6 months. If you are offered an interview and are unsuccessful we will retain your data for 12 months.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. We do ask you to allow us time to make the changes which we will generally be able to complete within 5 working days.
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 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. Please refer to our DSAR Procedure for more information.
- Request correction 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 Officer via email email@example.com
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer by email (firstname.lastname@example.org). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO via email (email@example.com).
Should your complaint show that we have breached our duty of care we will report the breach to the Information Commissioner’s Office (ICO). If you are not satisfied by our response 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. The ICO’s contact details are as follows:
Information Commissioner's Office
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. If you have any questions about this privacy notice, please contact our DPO, firstname.lastname@example.org