SCREWFIX RECRUITMENT PRIVACY NOTICE

1. Our Recruitment Privacy Notice

Screwfix Direct Limited (Company Number 03006378) of Trade House Mead Avenue Yeovil BA22
8RTis 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.

Screwfix 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:

• Personal 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.

• 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 information on professional or other

social networks and websites.

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.

• 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, recruitment
consultant or background check provider; and sometimes collect additional information from
professional or other social networks and websites, and 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.

• Where we need to protect your vital interests (or someone else’s interests).
 • Consent – in limited circumstances, with your consent.

The purposes for which we will process your personal information are listed below, along with the
key legal basis for each processing.

• Identifying candidates for potential employment, as well as for future roles that may
become available. (Legitimate Interests)

• Planning 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 post-employment screening checks. (Legitimate Interests)

• Equal opportunities monitoring. (Legal Obligations)

• Complying with legal or regulatory obligations placed on us regarding 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)

• Sharing your details with other companies in the Kingfisher group, where we or they believe
you may be suitable for a current or future role with them, and where you have indicated
that you would like your details to be shared with other group companies for this purpose.
(Legitimate Interests)

• Keeping in touch with you about [news, events and information about Screwfix that we
believe may be of interest to you]. (Consent)

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.

• 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. (Employment Rights and Obligations)

8. Do we need your consent?

We use your personal information on the basis of your consent in the circumstances described in
this notice. In limited circumstances, we may also 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.

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.

Please note that we will ask whether you have a lawful right to work in the UK, and if you are unable
to confirm this then we will automatically de-select your application as we are not legally able to
employ you without you having a lawful right to work in the UK.

11. Sharing your personal information with third parties

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

• Other entities within the Kingfisher group specifically Kingfisher plc, B&Q and Kingfisher
Information Technology Services (UK) Limited.

• Third-party service providers (including contractors and designated agents) who provide
candidate recruitment, interview and assessment services to us, or undertake background
screening or post-employment checks 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.

We may also share your details with other companies in the Kingfisher group, where we or they
believe you may be suitable for a current or future role with them, and where you have indicated
that you would like your details to be shared with other group companies for this purpose.

12. Transferring your personal information outside the EU

We will transfer the personal information we collect about you to the countries listed in the table
below in connection with our recruitment process and in order to process your application.

To ensure that your personal information receives an adequate level of protection we have put in
place the following appropriate measures to ensure that your personal information is treated by the
relevant third parties in a way that is consistent with and which respects the EU and UK laws on data
protection:

Service Countries of Transfer Protection Mechanism

Email and USA, Hong Kong, India, Canada, Model Data Protection Clauses
collaboration China, Egypt, Israel, Japan, incorporated into supplier contract (Article
Singapore 46, General Data Protection Regulation)

Candidate Singapore and USA Model Data Protection Clauses to be

recruitment and incorporated into supplier contract (Article
advertising and 46, General Data Protection Regulation)
services

Candidate US Model Data Protection Clauses to be

assessment incorporated into supplier contract (Article
services 46, General Data Protection Regulation)
(psychometric
testing)
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 where 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
nine (9) 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 transferred to your Human Resources file and retained during your working
relationship with us. The periods for which your personal information will be held will be
communicated to you in our privacy notice for employees, workers and contractors.

15. Your rights regarding 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). Please
note that this right does not apply in some cases, such as where we are required by law to
retain your data or where the data is required for us to bring or defend a legal claim.

• 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 described in this section). However, we may charge a reasonable fee if your request 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 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:

• Phone: 03330 112 112

• Email: data@screwfix.com

• Post: Data Protection Officer, Screwfix Direct Limited, Trade House, Mead Avenue, Yeovil
BA22 8RT

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. Their contact details are:

• Email: casework@ico.org.uk

• Phone: 0303 123 1113 (local rate) or 01625 545 745

• Post: Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9
5AF.

• Website: www.ico.org.uk

19. Changes to this privacy notice

We reserve the right to update this privacy notice at any time.