Overview
This Personal Data Privacy Notice for Job Applicants describes the types of personal data (which we will be calling “your information” or your “personal information”) that we collect, how we use it, how and when it may be shared, and how to exercise your rights with respect to your information. Our goal is to clarify how and why we process your information and to provide you with points of contact, should you have any questions about our policies or procedures. Thank you for taking the time to read and understand our data and privacy-related practices.
Applicability and Scope – Job Applicant Personal Data Privacy Notice
This Job Applicant Personal Data Privacy Notice (“Privacy Notice”) applies to the information collected from job applicants, professional service providers, and seasonal workers during the course of your applying to work at the Company or during your work placement with us (for professional service providers and contingent workers).
This Privacy Notice applies to your relationship with Soul Foods Group of companies and its respective subsidiaries and affiliated companies.
This Privacy Notice provides a standard for Soul Foods Group of companies (the Company) with respect to its protection of information. The jurisdiction where you reside may require different levels of protection. Therefore, we will handle your information in accordance with applicable laws and regulations at the place where the information is collected and processed. Where applicable local law provides a lower level of protection than that established by this Privacy Notice, we will still strive to meet the requirements of this Privacy Notice.
This Privacy Notice does not cover your use of products or services as a customer or any collection of information outside of the job application process with a Soul Foods Group UK group of companies.
This Privacy Notice for Job Applicants does not cover current full-time or part-time Soul Foods Group of companies’ employees , workers or contractors – if you fall into one of these categories, please contact HR for a copy of the Personal Data Protection Privacy Notice for Employees, Workers and Contractors – at: hrfoodsupport@soulfoodsgroup.com or hrcoffeesupport@soulfoodsgroup.com
Updates to this Privacy Notice for Job Applicants
Personal Data Privacy Notice for Job Applicants Last updated: 4 July 2023 2 We may update this Privacy Notice from time to time. When we make material changes to this Privacy Notice, we will notify you and will update the Last Revised date on this Privacy Notice. We encourage you to look for updates and changes to this Privacy Notice from which you accessed it to learn about any updates to this Privacy Notice.
Information We Collect
Subject to applicable law requirements, the categories of information that we may collect, store, and use about you include:
- Identifiers, such as your real name, postal address, date and place of birth, usernames, personal email address, and home or wireless phone number.
- Government-issued identification numbers, such as driver’s license number, passport number, national insurance number, right to work documents.
- Demographic information and characteristics of protected classifications, such as race or ethnicity, nationality, languages spoken, marital status, disability, gender
- Employment-related information, such as: · effective dates and years of service, work location, salary/pay/benefits, current/prior work record, and other career history information; · information required for compliance and risk management, such as disciplinary records, background check reports and security data; and
- employment eligibility information, including right-to-work, immigration status, refugee status, work permits, and residence status.
- Education information such as your educational status, certificates and licenses, degrees earned, vocational records and in-house training attendance, including as part of resumes/CVs;
- Internet and other electronic network activity, in particular your usage of Soul Foods Group of companies’ assets such as its computers and telecommunication systems (“IT”), and traffic generated on the Internet, including emails sent and received, building and information system access, and Soul Foods Group of companies device/system/application usage when accessing and using Soul Foods Group of companies buildings, stores, restaurants, networks, company-issued devices, and/or assets, and information related to a Soul Foods Group website.
- Audio, electronic, and visual information, such as photographs and video footage, subject to applicable law requirements.
If we ask you to provide any other information not described above, then we will make clear to you what specific information we need and the reason(s) why we ask you to provide it.
We also may collect information automatically from you. For instance, when you apply to a position using an online application portal, we may gather information from using cookies and other tracking technologies.
Please note that if you decline to provide certain information when requested, we may not be able to fulfil our responsibilities (e.g., paying you or providing a benefit), or we may be prevented from complying with our legal obligations (e.g., safeguarding the health and safety of non-employees present in our facilities). Therefore, if you do not provide certain information, we will not be able to enter into a contract with you or accept your engagement.
Sensitive Personal Information
Certain types of information may be subject to additional requirements under applicable laws. Data protection laws around the world may use varying terminology in naming these categories of sensitive data (such as “Special Categories of Personal Data” or “Sensitive Personal Information”), and also set requirements for companies to follow in their processing of such sensitive data.
Further, Soul Foods Group of companies may also internally identify certain categories of Sensitive Personal Information as “SPI.” We define SPI to be any information relating to an identifiable person that includes or implies race, ethnicity, political views, religion, health, sexual orientation, genetic or biometric data, union membership, information about criminal convictions and offenses, and other categories of information defined as sensitive information under applicable laws.
Company-Related Sensitive Personal Information Only Soul Foods Group of companies processes and uses your Sensitive Personal Information in two ways:
- 1. as required for business and employment purposes (e.g., recording work disabilities or injuries, etc.); and
- 2. based on your consent if you use company-sponsored services or platforms that might gather this type of data (e.g., a company-approved health and wellness application).
With this in mind, Soul Foods Group of companies processes Sensitive Personal Information to provide you with company benefits, comply with applicable laws or a valid request from law enforcement or courts, and/or to protect your data from cybersecurity threats. If you have questions about what Sensitive Personal Information is, and/or how Soul Foods Group of companies handles such data, please contact us at: soulcareers@soulfoodsgroup.com
Sources of Information In addition to the information we receive from you, we also receive the categories of information described above from other sources, including from government entities, data analytics providers, internet service providers, social networks, background verification providers, recruiters, agencies, market research companies, and business and service providers. How We Use Your Information
(a)Business Purposes – Soul Foods Group of companies requires your information to allow us to perform our duties as an employer and to enable us to comply with our legal obligations. We use your information in compliance with applicable laws, and we do so primarily to manage our relationship with you for the following business purposes:
- To administer the non-employee relationship or other commitments we have made to you, including to assess qualifications for a particular job or task or to communicate with you about your application or engagement;
- To administer pay, such as monitoring salary details and processing payment account details, and other compensation, and payroll administration (e.g., salary, tax withholding, etc.);
- For workforce development, talent management, education, training and certification;
- For business management and operations, such as to generate business analytics, to interact with you through online chats, and to conduct fraud prevention;
- For professional issues resolution, such as in relation to grievances, auditing, conflict of interest reporting, or to gather evidence for disciplinary action or ending an engagement;
- To identify a contact point in the event of an emergency, to further the health and safety needs for our workforce;
- For accounting, financial reporting and business planning;
- To ensure the safety and the security of Soul Foods Group of companies held information, including as part of business continuity planning and disaster recovery, and risk and security incident management;
- As required or expressly authorized by laws or regulations applicable to our business or by government agencies that oversee our business, or as part of legal proceedings and government investigations, including preservation of relevant data; and
- For any other business purposes that are reasonably required by Soul Foods Group of companies in connection with application for and during the course of your application process or engagement with any Soul Foods Group of companies.
(b) Compatible Purposes – We use your information as reasonably necessary for the purposes for which it was collected, unless we reasonably consider that we need it for another purpose that is compatible with the original purpose and there is a legal basis for further processing, if required.
(c) Accuracy – It is important that the information we hold about you is accurate and current. Please keep us informed if your information changes during your working relationship with Soul Foods Group of companies.
(d) Specific Consent – Depending on the location in which you reside, local laws may require that you provide specific consent for the collection, use and disclosure of your information for some of these purposes. Where required, you may be asked to provide your consent by appropriate and permitted means.
How We Disclose Your Information
Soul Foods Group of companies disclose your information as needed to fulfill the purposes described in this Privacy Notice and as permitted by applicable law. The circumstances for which we may disclose your information include the following:
(a) When We Work Together – We may share information between and among Soul Foods Group of companies and its subsidiaries, and affiliated companies for purposes of management and analysis, decision making, and other human resources and employment-related business purposes.
(b) When We Work with Service Providers & Other Third Parties – We may share identifiers, commercial information, electronic and network activity, geolocation and precise geolocation information, audio and video information, and inferences, as described above, for a variety of business purposes, such as such as payroll services and administration, IT services and website hosting, health and safety compliance, facilities management, email and postal delivery.
(c) When We Work on Business Transactions – If we become involved with a merger, reorganization, corporate transaction or another situation involving the transfer of some or all of our business assets, we may share your information with business entities or people involved in the negotiation or transfer.
(d) When Sharing Helps Us Protect Safety and Lawful Interests – We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, if we believe it will assist in the investigation of suspected or actual illegal activity, or if we believe that the disclosure will help us protect the rights, property, or safety of Starbucks, our customers or our partners.
(e) When You Give Consent – We may share information about you with other companies if you give us permission or direct us to share the information, in accordance with applicable law.
Please note that there may be certain situations where you will be asked or have the option to disclose your information directly with providers connected to a Soul Foods Group UK employee or non-employee services, where Soul Foods Group does not control how your data is processed. In those situations, please ensure you read and understand the privacy policies and practices of such providers.
Soul Foods Group UK has not sold and will not sell any non-employee information or share any non-employee information for purposes of cross-contextual behavioural advertising.
How We Protect Your Information
Soul Foods Group UK uses reasonable technical, physical, and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information. However, no security system is perfect, and due to the inherent nature of the internet, we cannot guarantee that data, including your information, is absolutely safe from intrusion or other unauthorized access by others. We ask that you be responsible in protecting your password(s) and maintaining the security of your devices.
Retention
(a) Data Retention Purpose and Location – Soul Foods Group of companies’ stores your information as reasonably necessary and proportionate to accomplish the purposes identified in this Privacy Notice based on criteria such as the length of time of your employment, and to meet legal requirements, including record retention, resolving disputes, and enforcing our agreements. This storage period may extend beyond the term of your job application process or engagement with Soul Foods Group of companies. Our retention of your information is subject to applicable law. The information that you provide us is stored and processed on servers owned by Soul Foods Group of companies and other companies in the UK and Canada. Regardless of the entity or person who processes your information and where it is processed, we will take steps to transfer and protect your information through appropriate safeguards in accordance with applicable data protection laws and this Privacy Notice.
(b) Retention Period – When your information is no longer needed or, in any event, after legal authority to retain it has expired, your information may be destroyed, in accordance with applicable law and pursuant to procedures established in relation to the relevant Soul Foods Group of companies system or process.
Transferring Your Information Overseas
Soul Foods Group of companies is a global business. As noted above, we and our service providers may collect, use, process, store or disclose your information outside your home country or jurisdiction, including in the UK and elsewhere, that may have different data protection laws than the laws where you reside or work.
Please note that Soul Foods Group of companies would only transfer non-partner information to another country (including to affiliates and subsidiaries within the Soul Foods Group of companies) in accordance with applicable laws and this Privacy Notice
Your Rights
Some of our job application portals and self-service tools allow you to view and update the personal information that Soul Foods Group of companies holds about you. If we have certain information about you that you cannot access via these self-service systems, or if we have information about you that you believe is inaccurate or no longer relevant, and you would like us to correct or delete such data, then you may make a request via: soulcareers@soulfoodsgroup.com
You have the following rights:
- right of access to personal information
- right to correct inaccurate personal information
- right to have their personal information deleted (within certain limits)
- right to restrict use of their personal information in certain circumstances
- right to have a copy of their personal information provided to them in a commonly used machine-readable format (to allow easy transfer to another data controller)
- right to object to the use of personal information where it is based on specific legal basis
- right to object to the use of automated decision making, including profiling.
If you have questions about this Privacy Notice or our personal information practices, please contact the Soul Foods Group at: soulcareers@soulfoodsgroup.com