Privacy Policy

The White Company collects and processes personal data relating to all applicants who apply for a role with us. We are committed to ensuring complete transparency regarding how we collect and use your data, and to adhering to the General Protection Regulation (GDPR), the Data Protection Act 2018 and all applicable data protection requirements imposed by law. In order to adhere to the data protection principles associated with the GDPR, we commit to ensuring that any personal data handled by The White Company is:

• Processed lawfully, fairly and transparently
• Collected for specified, explicit and legitimate purposes
• Adequate, relevant and limited to what is necessary
• Accurate and kept up to date where necessary
• Kept for no longer than is necessary where data subjects are identifiable
• Processed surely and protected against accidental loss, destruction or damage

During the recruitment process, The White Company will collect the following information about you:

• Your name, address and contact details, including your email address and telephone number
• Details of your qualifications, skills, experience and employment history
• Information about your current level of remuneration, including benefit entitlements
• Whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process – we process such information to carry out our ob- ligations under the UK’s disability rights and anti-discrimination legislation
• Information about your entitlement to work in the UK
• Equal opportunities information for the purposes of establishing equal opportunities and anti- discrimination practices as provided by the DPA 2018 and the Equality Act 2010
• Other supplementary information submitted as part of the recruitment process

This information is referred to as your "personal data".

Where it is necessary to collect and process any special categories of sensitive personal data, we will ensure it is handled with the utmost discretion and will limit access to the information to the indi-viduals who require it for the purposes of which it is being requested or processed

The White Company will collect this information from you via the following methods:

• The White Company Careers website registration information
• Online application form and Curriculum Vitae via our website or Social Networking platforms
• Right to Work documentation
• Interview and assessment forms
• Social Sign-Up i.e. Google Suite, Facebook, LinkedIn
• Third party recruitment agencies

We will also collect personal data about you from third parties, such as references supplied by former employers. We will only seek this information once a job offer has been made to you, if and when you are successful during the recruitment process, and we will inform you that we are doing so.

Your personal data will be stored in a range of different places, including in your The White Company Careers account, on your online application form, in our applicant tracking system, on our internal IT systems and in lockable cabinets/files.

We will process your process data at the start of and during the recruitment process. If you are successful with your application, we will process your data during the course of your employment to ensure that we fulfil our employment obligations.

We collect and process your data during the recruitment process in order to manage the recruitment process and to assess your suitability for potential employment with The White Company. We rely on the following lawful basis to obtain and use your Personal Data.

We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

Where we rely on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of employees or workers and we have concluded that they are not.

We will also need to collect and process your data to ensure that we are complying with our legal obligations i.e. eligibility to work in the UK.

We ask for consent to reach out with updates on new vacancies and to keep your data on our system for an additional year for this purpose. If no consent is given, then your records will be automatically archived from our system.

The White Company needs to process your personal data to take steps at your request, prior to entering in a pote ntiall employment contract with you.

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the Talent and People teams, Hiring Managers involved in the recruitment process within the business area with the relevant vacancy, and a third-party provider, eArcu, who provide the platform and facilitate the online applicant tracking and management system.

The White Company and eArcu will not share your data with other third parties unless your application is successful, and we make an offer of employment. We will then share your data with former employers to obtain references for you.

In addition, if successful in an appointment at The White Company, we may need to share your personal information with a regulator or otherwise to comply with the law.

If your application for employment is successful, The White Company may share your personal data with third- party processors who provide services to the organisation. These services include:

• Insurance Providers
• Pension Providers
• Third party recruitment agencies
• Employment and credit reference agencies
• Information about your entitlement to work in the UK

You will be asked when you submit your CV whether or not you agree to us holding your personal information. Your personal information will be held for different retention periods based on our lawful grounds of processing personal data and will be held no longer than what is necessary. Retention periods will also depend on whether your application for employment with The White Company is successful or not.

If your application for employment with The White Company is successful, any personal information obtained during the recruitment process will be transferred to your Employee Personnel File (electronic and paper based) and retained for the duration of your employment with The White Company. The periods for which your data will be held will be detailed to you in a separate privacy notice upon commencing your employment with The White Company.

If your application for employment with The White Company is unsuccessful, we will hold your information on file for 1 year after the end of the recruitment process with your consent when opting-in to be considered for future opportunities.

Then, if you have agreed to allow us to keep your personal data on file an email will be sent to you after 1 year to refresher your consent, if you give your consent we will hold your data on file for a further 1 year in order to be considered for any future employment opportunities which may arise. At the end of that period, or if at any point prior to this point if you request it, your data will be deleted or destroyed (unless we need to retain it for longer to exercise or defend any legal claims).

The White Company take the security of your information very seriously. We have internal policies and controls in place to ensure that your information is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

Where we engage third parties to process personal data on our behalf or we share personal data with third parties, those third parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

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.

As a data subject, have the right to:

• Access and obtain a copy of your data on request
• Require The White Company to change incorrect or incomplete information
• Require The White Company to delete or stop processing your information, for example where the information is no longer necessary for the purposes of processing; and
• Object to the processing of your data where The White Company is relying on its legitimate inter- ests as the legal ground for processing

If you would like to exercise any of these rights, please reach out to dpo@thewhitecompany.com.

If at any time you believe that The White Company has not complied with your data protection rights, please email dpo@thewhitecompany.com to allow us to consider your complaint and rectify it. If you are unhappy with our response, you may submit a complaint to the Information Commission-er’s Office.

Whilst you are under no statutory or contractual obligation to provide your personal data to The White Company during the recruitment process, failure to do so may result in your application not being processed.

The White Company Ltd is the controller of data for the purposes of GDPR. If you have any concerns as to how your data is processed, please email dpo@thewhitecompany.com.