Recruitment Privacy Notice

1. Our Recruitment Privacy Notice

Kingfisher Information Technology Services (UK) Ltd is committed to protecting the privacy and security
of your personal information.

This privacy notice describes how we collect and use personal information about you during and after
our application and recruitment processes. It applies to all current and former job applicants and
potential candidates for employment.

Kingfisher Information Technology Services (UK) Ltd is a "data controller" with regard to the personal
information we hold about you by virtue of your involvement in our recruitment processes. This means
that we are responsible for deciding how we hold and use personal information about you. We are
required under data protection law to notify you of the information contained in this privacy notice.

This privacy notice does not form part of any contract of employment or other contract to provide
services offered to candidates hired by us.

It is important that you read this notice, together with any other privacy notice we may provide on specific
occasions when we are collecting or processing personal information about you, so that you are aware
of how and why we are using this information.

2. Data protection principles

We comply with data protection law, meaning that the personal information we hold about you must be:

• used lawfully, fairly and in a transparent way;

• collected only for valid purposes that we have clearly explained to you, and not used in any
way that is incompatible with those purposes;
• relevant to the purposes for which we use it;
• accurate and kept up to date;
• kept only as long as necessary for the purposes for which we use it;
• kept securely.

3. The kind of information we hold about you

Personal information means any information about an individual who 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:

• Contact details, such as name, title, addresses, telephone numbers, and personal email
addresses;
• employment records, including job titles, work history and professional memberships;
• education history, including achievements and test results;
• copies of right to work documentation;
• compensation history;
• assessment performance information;
• references;
• photographs and images from recorded assessments or from on-site CCTV footage.
• results of pre-employment screening checks, such as credit history.

We may also collect, store and use the following "special categories" of more sensitive personal
information, which require a higher level of protection:

• information about your race or ethnicity;

• trade union membership;
 • Information about your health, including any medical condition, health and sickness records;

We may also capture information about any criminal convictions and offences, as explained further in
the “Information about criminal convictions and offences” section below.

4. How is your personal information collected?

We usually collect personal information directly from you when you apply for a role with us, such as
information included in CVs, application forms, application videos or cover letters.

We may also collect personal information about you from an employment agency or background check
provider; and sometimes collect additional information from third parties including former employers,
credit reference agencies or other background check agencies.

5. When and how we will use your personal information

We will only use your personal information when the law allows us to. Most commonly, we will use your
personal information in the following circumstances:

• Legal Obligations – where we need to comply with a legal obligation.

• Legitimate Interests – where it is necessary for our legitimate interests (or those of a third party),
and your interests and fundamental rights do not override those interests.
• Pre-Contract Steps – where it is necessary in order to take steps at your request prior to
entering into a contract of employment, or other contract to provide services, with you.
• Other – in the following situations, which are likely to be rare:
o Where we need to protect your vital interests (or someone else’s interests).
o Where it is needed in the public interest or for official purposes.

The purposes for which we will process your personal information are listed below, along with a key
legal basis for each processing.
• Identifying candidates for potential employment, as well as for future roles that may become
available. (Legitimate Interests)
• Making a decision about your recruitment or appointment. (Legitimate Interests)
• Determining the terms on which you work for us. (Legitimate Interests)
• Checking you are legally entitled to work in the UK. (Legal Obligations)
• To prevent fraud. (Legitimate Interests)
• Conducting pre-employment screening checks. (Legitimate Interests)
• Equal opportunities monitoring. (Legal Obligations)
• Complying with legal or regulatory obligations placed on us with regard to our hiring, such as
those relating to candidates with disabilities. (Legal Obligations)
• Dealing with legal disputes involving you and protecting our legal rights to the extent authorised
or permitted by law. (Legitimate Interests)
• Complying with health and safety obligations. (Legal Obligations)
• Recordkeeping in relation to our recruitment processes. (Legitimate Interests)

Some of the above grounds for processing will overlap and there may be several grounds which justify
our use of your personal information.

In addition, we require a further legal basis if the information is in a “special category” of personal
information. See the “When and how we use particularly sensitive personal information” section below
for more detail.

6. If you fail to provide personal information

If you fail to provide certain personal information when requested, which is necessary for us to consider
your application (such as evidence of qualifications or work history), we will not be able to process your
application successfully. For example, if we require references for a role and you fail to provide us with
relevant details, we will not be able to take your application further.
7. When and how we use particularly 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
have in place an appropriate policy, documents and safeguards which we are required by law to
maintain when processing such information. We may process special categories of personal information
in the following circumstances:

• Employment Rights and Obligations – where we need to carry out our legal obligations or
exercise rights in connection with employment.
• Public Interest – where it is needed in the public interest on the basis of national or EU law,
such as for equal opportunities monitoring.
• Explicit Consent – in limited circumstances, with your explicit written consent.
• Other – less commonly:
o Where it is needed in relation to legal claims.
o Where it is needed to protect your vital interests (or someone else's interests) and you
are not capable of giving your consent.
o Where you have already made the information public.

We will use your particularly sensitive personal information in the following ways and on the basis of
the legal grounds specified.
• We will use information about your disability status to consider whether we need to provide
appropriate adjustments during the recruitment process, such as to enable you to take online
assessments and attend interviews. (Employment Rights and Obligations)
• We will use information about your race or ethnic origin to ensure meaningful equal opportunity
monitoring and reporting. (Public Interest)
• We will use trade union membership information to comply with employment law obligations
relating to the hiring of trade union members. (Employment Rights and Obligations)

8. Do we need your consent?

We do not need your consent if we use your personal information in accordance with our written policy.
In limited circumstances, we may approach you for your written consent to allow us to process certain
particularly sensitive information. If we do so, we will provide you with full details of the information that
we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
You should be aware that it is not a condition of any contract you may enter into with us that you agree
to a request for consent from us.

You can withdraw your consent at any time – please see the “Right to withdraw consent” section below
for more detail.

9. Information about criminal convictions and offences

We may collect information about your criminal convictions history if it is appropriate given the nature
of the role and where the law allows us to do so. This will usually be where such processing is necessary
to carry out our legal obligations or exercise rights in connection with employment, and provided we do
so in line with Kingfisher’s 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 vital interests (or someone else’s interests) and
you are not capable of giving your consent, or where you have already made the information public.

10. Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make
a significant decision without human intervention. We are allowed to use automated decision-making in
the following circumstances:

• Where we have notified you of the decision and given you 1 month to request a reconsideration
or to request that we take a new decision that is not based solely on automated processing.
 • Where it is necessary to perform the contract with you and appropriate measures are in place
to safeguard your rights.
• In limited circumstances, with your explicit written consent and where appropriate measures
are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we
must have either your explicit written consent or it must be justified in the public interest, and we must
also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated
decision-making unless we have a lawful basis for doing so and we have notified you.

11. Sharing your personal information with third parties

We will only share your personal information with third parties for the purposes of processing your
application. Third parties include:

• Other entities within the Kingfisher group – please see www.kingfisher.com for a list of the
Kingfisher group entities with whom we may share your information in this way.
• Third-party service providers (including contractors and designated agents) who provide
candidate recruitment, interview and assessment services to us, or undertake background
screening on our behalf.
• Former employers, for the purposes of obtaining references from you.

All our third-party service providers and other entities in the group are required to take appropriate
security measures to protect your personal information in line with our policies. We do not allow our
third-party service providers to use your personal information for their own purposes. We only permit
them to process your personal information for specified purposes and in accordance with our
instructions.

12. Transferring your personal information outside the EU

We will transfer the personal information we collect about you to the following countries outside the EU:
India, Mexico, United States, Hong Kong, Canada, China, Egypt, Morocco, Israel, Japan, Singapore, in
order to process your application. Except for Canada and Israel, there is not an adequacy decision by
the European Commission in respect of those countries. This means that the countries to which we
transfer your personal information are not deemed to provide an adequate level of protection for your
personal information.

However, to ensure that your personal information does receive an adequate level of protection we
have put in place the following appropriate measures to ensure that your personal information is treated
by those third parties in a way that is consistent with and which respects the EU and UK laws on data
protection, namely standard contract clauses (article 46 GDPR)

13. Keeping your personal information secure

We have put in place appropriate security measures to prevent your personal information from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal information to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal information on our instructions
and they are subject to a duty of confidentiality. For details of these measures, please contact us using
the “How to contact us” section below.

We have put in place procedures to deal with any suspected data security breach and will notify you
and any applicable regulator of a suspected breach where we are legally required to do so.

14. How long we will use your personal information for

If your application with us is unsuccessful, we will hold your personal information for a period of 6 months
after we have communicated that decision to you. We retain your personal information for that period
so that we can show, in the event of a legal claim, that we have not discriminated against candidates
on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent
way. After this period, we will securely destroy your personal information in accordance with the
Kingfisher Record Keeping and Document Retention Policy and Standard.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise
in future and we may wish to consider you for that, we will write to you separately, seeking your consent
to retain your personal information for a fixed period on that basis.

If your application with us is successful, the personal information gathered during the recruitment
process will be retained during your working relationship with us. The periods for which your personal
information will be held will be communicated to you.

15. Your rights in connection with your personal information

By law you have the right to object to processing of your personal information in certain circumstances,
where 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.

You also have the right by law under certain circumstances 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.
• 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, for example, 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 above).
• 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.

You will not have to pay a fee to access your personal information (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or
excessive. Alternatively, we may refuse to comply with the request in such circumstances.

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 another appropriate
security measure to ensure that personal information is not disclosed to any person who has no right
to receive it.

If you want to exercise these rights, please contact us using the details in the “How to contact us” section
below.

16. 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 us using the
details in the “How to contact us” section below.

Once we have received notification that you have withdrawn your consent, we will no longer process
your personal information for the purpose or purposes you originally agreed to, unless we have another
legitimate basis for doing so in law.
17. How to contact us

If you have any questions about this privacy notice or how we handle your personal information, or if
you would like to exercise any of the rights set out in the “Your rights in connection with your personal
information” section above, please contact us using your preferred method of the following:

• Email: dpo@kingfisher.com
• Post: Data Protection Officer, Kingfisher Information Technology Services (UK) Ltd, 3 Sheldon
square, London W2 6PX, United Kingdom.
• Telephone: 020 7372 8008

18. Complaints

If you are concerned about how we use your personal information, you have the right to make a
complaint at any time to either the Information Commissioner's Office (ICO), the UK supervisory
authority for data protection issues, or (if different) the supervisory authority in your place of residence
or the place in which the relevant infringement has taken place.