Privacy Policy

Scope Of Privacy Notice

  1. dmg media (“we” or “dmg media”) values the trust of our staff. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor).
  2. Like most businesses, we hold and process a wide range of information, some of which relates to individuals who are applying to work for us. This notice explains the type of personal data we process, why we are processing it and how that processing may affect you. It also outlines the rights available to you under applicable data protection laws.

    The notice focuses on individuals who are applying to work for us (including those that may be unsuccessful in the application process) and the data we process as a data controller as part of that process in accordance with applicable data protection laws. We have a separate Workplace Privacy Notice that applies to our current and former employees.

  3. In brief, this notice explains:
    • what personal data we hold and why we process it;
    • the legal grounds which allow us to process your personal data;
    • where the data comes from, who gets to see it and how long we keep it;
    • how to access your personal data and other rights;
    • how to contact us.

Personal Data – What We Hold And Why We Process It

  1. We process personal data for the purposes of our business including recruitment, management, administrative, employment and legal purposes. See section 14 (Further Information On The Personal Data We Process And Our Purposes) for additional information.

Where The Personal Data Comes From And Who Gets To See It

  1. Some of the personal data that we process about you comes from you. For example, you tell us your contact details and work history. If you are joining us, you may provide your banking details.

    Other personal data may come from third parties such as recruiters acting on your behalf or from your references.

    Your personal data will be seen internally by managers, HR, others involved in the interview process and, in some circumstances (if you join us) other colleagues. We will where necessary and as set out in this privacy notice also pass your data outside the organisation, for example to people you are dealing with and the Disclosure and Barring Service, and other background checking and credit agencies (if applicable to the role for which you are applying).

If You Fail To Provide Your Personal Data

If you fail to provide 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 a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

How Long Do We Keep Your Personal Data?

  1. In general, if you become employed by us we will keep your personal data for the duration of your employment and for a period of 6 years afterwards. If you are unsuccessful in gaining employment with us, we will keep your personal data for 12 months after informing you that you were unsuccessful, so that your application can be considered for other suitable positions which become may available.

Transfers Of Personal Data Outside The EEA

  1. We will where necessary and as set out in this privacy notice transfer your personal data outside the UK and EEA to members of our group and trusted third parties in other jurisdictions in which we are established.

Your Data Rights

  1. You have a right to make a subject access request to receive information about the data that we process about you. You also have other rights, outlined in more detail below.

Contact Details

  1. In processing your personal data, we act as a data controller. Our contact details are set out in this notice.

    Please note that generally the data controller of your personal data will be your employing/engaging entity (or the employing/engaging entity that you apply to work for) but also entities within DMGT plc and its group companies with which we share data for business administration purposes.

Status Of This Notice

  1. This notice does not form part of any contract of employment you might enter into and does not create contractual rights or obligations. It may be amended by us at any time. If you are in the application process when any changes or updates are made to this notice, we will bring any such changes to your attention as soon as practicable. We may also notify you in other ways from time to time about the processing of your personal data. Nothing in this notice is intended to create an employment relationship between ANL and any non-employee.

What Do We Mean By “Personal Data” And “Processing”?

  1. “Personal data” is any information about a living individual from which that person can directly or indirectly be identified. It includes not only facts about you, but also intentions and opinions about you.

    “Processing” means doing anything with the data. For example, it includes collecting it, holding it, disclosing it and deleting it.

    Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by UK and EU privacy law to be “special category” or “sensitive” personal data.

    References in this notice to employment, work (and similar expressions) include any arrangement we may have under which an individual provides us with work or services, or applies for such work or services. By way of example, when we mention an “employment contract”, that includes a contract under which you provide us with services; when we refer to ending your potential employment, that includes terminating a contract for services. We use the word “you” to refer to anyone within the scope of the notice.

Legal Grounds For Processing Personal Data

What Are The Grounds For Processing?

  1. Under data protection law, there are various grounds on which we can rely when processing your personal data. In some contexts, more than one ground applies. We have summarised these grounds as Contract, Legal obligation, Legitimate Interests, Vital interests and Consent and outline what those terms mean in the following table.

    Term Ground for processing Explanation
    Contract Processing necessary for performance of a contract with you or to take steps at your request to enter a contract This covers carrying out our contractual duties and exercising our contractual rights.
    Legal obligation Processing necessary to comply with our legal obligations Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination.
    Legitimate Interests Processing necessary for our or a third party’s legitimate interests We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data.

    Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.
    Consent You have given specific consent to processing your data In general processing of your data in connection with employment is not conditional on your consent. But there may be occasions where we do specific things such as provide a reference and rely on your consent to our doing so.
    Vital interests Processing necessary to protection yours (or someone else’s) vital interests This covers processing in an emergency situation where someone’s life may be in danger. For example, where providing someone’s name to a paramedic or first aider.

Processing Sensitive Personal Data

  1. We do not routinely process your sensitive, also known as “special category”, personal data. If we do process special category data about you (which for example can occur when we need to process information relating to your health so that we can provide you with any reasonably adjustments necessary during the recruitment process), as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one or more of the grounds for processing sensitive personal data applies. In outline, these include:
    • Processing being necessary for the purposes of your or our obligations and rights in relation to employment in so far as it is authorised by law or collective agreement;
    • Processing relating to data about you that you have made public (e.g. information that you post on professional networking sites);
    • Processing being necessary for protecting the vital interests of you or someone else when consent cannot be obtained;
    • Processing being necessary for the purpose of establishing, making or defending legal claims;
    • Processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity;
    • Processing for equality and diversity purposes to the extent permitted by law.
    • Disclosure and Barring Services (DBS) checks where we have a legal right or reason for doing so.

Further Information On The Personal Data We Process And Our Purposes

  1. The Core Notice outlines the purposes for which we process your personal data. More specific information on these, examples of the data and the grounds on which we process data are in the table below.

    Purpose Examples of personal data that may be processed Grounds for processing
    Recruitment Standard data related to your identity (e.g. your name, address, email address, ID information and documents, telephone numbers, place of birth, nationality, contact details, professional experience and education (including university degrees, academic records, professional licences, memberships and certifications, awards and achievements, and current and previous employment details), financial information (including current salary information) language skills, and any other personal data that you present us with as part of your application related to the fulfilment of the role.

    Information concerning your application and our assessment of it, your references, other information included in a CV or cover letter, any checks we may make to verify information provided or background checks and any information connected with your right to work, decisions to offer you employment, and psychometric test results (if applicable) etc

    If necessary, we will also process information concerning your health, any disability and in connection with any adjustments to working arrangements.
    Contract

    Legal obligation

    Legitimate interests

    Necessary for the purposes of rights and obligations in relation to employment
    Administering our recruitment process Evaluating your experience and qualifications against the requirements of the position you are applying for.

    Administering our applicant tracking system.

    Communicating with you in respect of any offer of employment we choose to make and providing you with information about our onboarding process.
    Contract

    Legal obligation

    Legitimate interests
    Entering into a contract with you (if you are made an offer by us) Information on your terms of employment from time to time including your hours and working patterns, your pay and benefits, such as your participation in pension arrangements, life and medical insurance; and any bonus or share schemes. Contract

    Legal obligation

    Legitimate interests
    Contacting you or others on your behalf Your address and phone number, emergency contact information and information on your next of kin. Contract

    Legitimate interests
    Physical and system security CCTV images upon attendance for interview at our premises. Legal obligation

    Legitimate interests
    Monitoring of diversity and equal opportunities Information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age as part of diversity monitoring initiatives. Such data will be aggregated and used for equality of opportunity monitoring purposes. Please note we may share aggregated and anonymized diversity statistics with regulators if formally required / requested. Legitimate interests

    Legal obligation
    Disputes and legal proceedings Any information relevant or potentially relevant to a dispute or legal proceeding affecting us. Legitimate interests

    Legal obligation
    Please note that if you accept an offer from us the business will process further information as part of the employment relationship. We will provide you with our full Workplace Privacy Notice as part of the on-boarding process.

Where The Data Comes From

  1. When you apply to work for us the initial data about you that we process is likely to come from you: for example, contact details, bank details and information on your immigration status and whether you can lawfully work. Where necessary and in accordance with this privacy notice, we will require references and information to carry out background checks. If you have concerns about this in a particular context, you should speak to your recruiter or our HR department.
  2. Please note we may also receive data from third party recruiters, agents and similar organisations as a part of the recruitment process.

Who Gets To See Your Data?

Internal Use

  1. Where necessary and as set out this privacy notice, your personal data will be disclosed to relevant managers, HR and administrators for the purposes of your application as mentioned in this document. We will also disclose this to other members of our group where necessary for decision making regarding your application – this will depend on the type of role you are applying for.

External Use

  1. We may 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 data outside the EU. If we do, you can expect a similar degree of protection in respect of your data. We will only disclose your personal data outside the group if disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you.

    We will disclose your data if it is necessary to administer the working relationship with you or for our legitimate interests as an organisation or the interests of a third party (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy). Where necessary, we will also disclose your personal data if you consent.
  2. Specific circumstances in which your personal data may be disclosed include:
    • To service providers and third party recruitment consultants and similar businesses (including online recruitment portals) as a part of the recruitment process;
    • Background check/credit check providers;
    • Disclosure of aggregated and anonymised diversity data to relevant regulators as part of a formal request (see above).
  1. 2 We may also share your personal data with other third parties for other reasons. For example: in the context of the possible sale or restructuring of the business; to provide information to a regulator; or to otherwise comply with the law. To comply with our legal obligations, we may share your data with the following:
    • HMRC for tax purposes;
    • Home Office for immigration purposes; and
    • DVLA to validate driving licence information if you drive company vehicles.

Retaining Your Personal Data – More Information

  1. In general, if you are successful in becoming employed by us, we will keep your personal data for the duration of your employment and for 6 years afterwards.

    If your data is only useful for a short period (for example, CCTV footage data) we will delete it.

    Personal data relating to job applicants (other than the person who is successful) will normally be deleted after 12 months, unless you specifically consent to us holding it for longer for the purpose of contacting you in the event that any similar jobs/roles become available from time to time or we are legally permitted to keep for a longer period.

Transfers Of Personal Data Outside The EEA – More Information

  1. In connection with our business and for employment, administrative, management and legal purposes, we will where necessary, and as set out in this privacy notice transfer your personal data to members of our group in other jurisdictions outside the UK and EEA in which we are established: USA, Australia, United Arab Emirates.
  2. There is not an adequacy decision by the UK or the European Commission in respect of the United Arab Emirates and Australia. There exists a partial adequate decision for the USA, relating to American companies who have signed up to the EU-US Privacy Shield Framework. Where a jurisdiction has not been found adequate by the UK or European Commission, this means that these countries are not deemed to provide an adequate level of protection for personal data. To ensure that your personal data does receive an adequate level of protection where it is transferred between Associated Newspapers locations we have put in EC standard contractual clauses for transfers of personal data. These are available from the legal team on request.
  3. In respect of any other transfers with third parties, we have put in place appropriate measures to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection, as set out in the table below.
    Transferring country Recipient country Basis for transfer Adequacy safeguard
    UK USA In order to perform a contract EC standard contractual clauses
    UK Australia In order to perform a contract EC standard contractual clauses
    UK UAE In our legitimate interests of Associated Newspapers EC standard contractual clauses
  4. We will ensure that any transfer is lawful and that there are appropriate security arrangements.

Your Duties

We encourage you to ensure that the personal data that we hold about you for the purposes of your application or for the purposes of considering you for any similar roles is accurate and up to date by keeping us informed of any changes to your personal data.

Access To Your Personal Data And Other Rights

  1. We try to be as open as we reasonably can about personal data that we process. If you would like specific information, just ask us.

    You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including:
    • Giving you a description and copy of the personal data
    • Telling you why we are processing it
    If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.

    Under certain circumstances, by law you also have the right to:
    • have your personal data corrected where it is inaccurate;
    • have your personal data erased where it is no longer required. Provided that we do not have any continuing lawful reason to continue processing your personal data, we will make reasonable efforts to comply with your request;
    • have your personal data be transferred to another person in an appropriate format where we process that data in reliance on your consent and the processing is carried out by automated means;
    • withdraw your consent to processing where this is our lawful basis for doing so;
    • restrict the processing of your personal data where you believe it is unlawful for us to do so, you have objected to its use and our investigations is pending, or you require us to keep it in connection with legal proceedings; and
    • to object to the processing of your personal data, where we rely on legitimate business interests as a lawful reason for the processing of your data. You also have the right to object where we are processing your personal data for direct marketing purposes. We have a duty to investigate the matter within a reasonable time and take action where it is deemed necessary. Except for the purposes for which we are sure we can continue to process your personal data, we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data.
    The way we process your personal data and the lawful basis on which we rely to process it may affect the extent to which these rights apply. If you would like to exercise any of these rights, please address them in writing by emailing us at dataprotection@dmgmedia.co.uk or, alternatively, emailing the Data Protection Officer (DPO) at DPO@dmgt.com.

    Please note that we may be required to ask you for further information in order to confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

    You have the right to complain to a supervisory body if you are concerned about the way we have processed your personal data. In the UK, this is the Information Commissioner’s Office (ICO) which you can contact at www.ico.org.uk.

    Although you have the right to complain to the ICO, we encourage you to contact us first with a view to letting us help in resolving any queries or questions.

Questions

  1. If you have any questions about any matter relating to data protection or the personal data that we process about you, please contact us at the following:

    Data Protection & Privacy, Associated Newspapers Ltd, Northcliffe House, Derry Street, London, W8 5TT

    Email: dataprotection@dmgmedia.co.uk

    Alternatively, you can contact our DPO at:
    Email: DPO@dmgmedia.co.uk