Privacy Policy

Effective Date: 11th July 2022

INTRODUCTION

This privacy notice explains what personal data (information) we will hold about you, how we collect it, how we will use and may share information about you during the application process and when you visit our website, and your rights in relation to your personal information, including the right to object to processing. We are required to notify you of this information, under data protection legislation. Please ensure that you read this privacy notice and any other similar notice or policy we may provide to you from time to time when we collect or process personal information about you.

This privacy notice applies to the recruitment activities of all companies owned directly or indirectly by Ocado Group plc, including where relevant, internal recruitment activities.

Currently, this includes:

United Kingdom: Ocado Central Services Limited
Poland: Ocado Polska Sp z.o.o.
Spain: Ocado Spain SLU
Bulgaria: Ocado Bulgaria EOOD
France: Ocado Solutions France SAS
Sweden: Ocado Solutions Sweden AB; and Ocado Sweden AB
USA: Ocado Solutions USA
Canada: Ocado Solutions Canada
Australia: Ocado Solutions Australia Pty Lmt
Japan: Ocado Solutions Japan KK

(each an “Ocado Group Company”) and references to ‘we’, ‘us’ and ‘our’ in this notice mean an Ocado Group Company.

Data Protection Officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information or you would like to contact us, please contact the DPO. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or your local supervisory authority for data protection issues (contact details below).

Contact details of the DPO:

Email: privacy@ocadogroup.com

Contact telephone number: +44 (0) 1707 227 800

Postal address: Data Protection Officer, Ocado Group, Buildings One and Two, Trident Place, Mosquito Way, Hatfield, Hertfordshire, United Kingdom, AL109UL.

Who collects the information

Each Ocado Group Company is a ‘data controller’ in each respective jurisdiction and where applicable, gathers, shares and uses certain information about you in line with this recruitment privacy notice. A data controller is the entity which determines the purposes for which and the manner in which your personal data is processed.

Data protection principles

We will comply with data protection law and principles, which means that your data will 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 we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

About the personal information we collect and process

The table set out in Part A of the Schedule below summarises the information we collect and hold up to and including the shortlisting stage of the recruitment process, how and why we do so, how we use it and with whom it may be shared. The table in Part B of the Schedule below summarises the additional information we collect before making a final decision to recruit i.e. before making an offer of employment unconditional, how and why we do so, how we use it and with whom it may be shared. We also use cookies and similar technologies in relation to our online recruitment activities and you should refer to our Cookie Policy for further information which is available on our website, careers.ocadogroup.com.

Where information may be held

Personal information may be held at our offices and those of our group companies, and third party agencies, service providers, representatives and agents. Personal information may be transferred internationally to countries in the EU, the UK, the USA, Canada and other countries around the world, including countries that do not have data protection and privacy laws equivalent to those in your local country. We have measures in place to seek to ensure that there is appropriate security for information we transfer or store outside the UK and the European Economic Area (EEA). In addition, if one of our UK or EEA-based group companies collects your personal information, they will use one or more of the following safeguards if they transfer your personal information to an organisation outside the UK and the EEA:

the organisation is based in a country which ensures a level of data protection which is equivalent to EEA or UK standards, as this has been determined by a European Commission decision and/or UK adequacy regulations;
the organisation is bound by European Commission-approved standard contractual clauses, which offer appropriate data protection safeguards, or equivalent standard clauses approved in the UK; or
a derogation applies in accordance with data protection laws (for example, you have provided your explicit consent, or the transfer of the data is necessary in order for Ocado to enter into a contract with you).

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, save for the exemptions to this rule i.e. if automated decision- making is required or authorised by law or is necessary for entering into or performing the contract or is based on your individual explicit written consent.

If you fail to provide personal information

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 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 we keep your information

We will normally retain your personal information for a period of six months after we have communicated to you our decision about whether to appoint you to the role, unless we are required to hold this for longer in your country (e.g. in Spain, we will hold onto your personal information for one year) or you consent to us holding your personal information for longer (as explained in more detail in the paragraph below). 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 our applicable data retention policy.

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 explicit consent to retain your personal information for a fixed period, usually two years, on that basis.

Your rights in connection with personal information

Under certain circumstances, by law you have certain rights in relation to your information depending on where you are applying:

UK & EEA Candidates

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 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 below). Please note that this is not an absolute right and that we will be able to retain certain information where we have a legitimate interest to do so.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
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.
Withdraw your consent for processing of your personal information (where your consent is required) at any time. However, if you withdraw your consent, this will not affect the lawfulness of any processing of your personal information carried out prior to the withdrawal of your consent.

Please note these rights may be limited, for example if fulfilling your request would reveal personal data about another person or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of the relevant exemptions upon which we rely when responding to any request you make.

If you want to exercise any of your data protection rights, please contact the DPO in writing. 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 an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

Sharing your personal information with third parties

Your personal information will primarily be accessed by our employees who are involved in your recruitment process, our HR, IT, finance and facilities departments, to the extent it is necessary for them to fulfil their tasks in relation to your application. We may share personal information with other Ocado group companies, when necessary in relation to the application process and with third parties as we describe below:

To process your application, to enable appropriate checks and aptitude tests to be carried out and to facilitate and undertake recruitment interviews on our behalf. For example, we work with Experian to help us carry out criminal record checks (only where this is legally permitted), recruitment and tracking systems providers, and the Driving and Vehicle Licensing Authority (DVLA) to conduct driving licence checks. We may also use third-party service providers, such as IT system and technology application providers, to process and store your personal information; and
in line with our Privacy & Cookie Policy (which is available on our website, careers.ocadogroup.com), to help us monitor website performance, utilisation of features and services, traffic and demographic trends, and browser versions, to improve our website and services and tailor them to your interests;
we share information with our business advisors, such as legal advisors or business/ recruitment consultants, to the extent it is necessary for them to provide us with their services;
we may share information with regulatory and government authorities and/or law enforcement agencies if required by law or if necessary for the legal protection of our legitimate interests in compliance with applicable laws;
in the event that our business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser's adviser and passed to the new owners of the business;
we may share information for the purposes of company reporting and analysis.

When we engage third-party service providers, we require that they 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.

How to complain

We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information.

However, for further information about your rights and how to make a formal complaint, in the first instance, please contact the Information Commissioner in the UK (as this is generally Ocado’s designated national data protection authority) at https://ico.org.uk/concerns/ or telephone: (+44) 0303 123 1113.

THE SCHEDULE

ABOUT THE INFORMATION WE COLLECT AND HOLD

Part A - Up to and including the shortlisting stage

The information we collect: Your name and contact details (i.e. address, home and mobile phone numbers, email address).

How we collect the information: From you.

Why we collect the information (legal basis): To be able to contact you and progress your application and to make an informed recruitment decision (our legitimate interests). To enter into/perform a contract with you (the employment contract) and/or to take steps at your request prior to doing so.

How we use and may share the information: To enable HR personnel or the manager of the relevant department to contact you to progress your application, arrange interviews and inform you of the outcome. To inform the relevant manager or department of your application.

The information we collect: Details of your qualifications, experience, CV, employment history including job titles, salary, notice period, and working hours and interests (if you provide us with this information)

How we collect the information: From you, in the completed application form, CV and interview notes (if relevant)

Why we collect the information (legal basis): To make an informed recruitment decision (our legitimate interests). To enter into/perform a contract with you (the employment contract) and/or to take steps at your request prior to doing so.

How we use and may share the information: To enable HR personnel or hiring managers in the relevant department to making shortlisting and hiring decisions. Used to make an informed recruitment decision.

The information we collect: Pre-screening comments based on telephone interviews, manager interview notes and aptitude testing results and notes

How we collect the information: From you in your completed application form, telephone and in- person interview notes, and from relevant aptitude testing.

The information we collect: Information regarding your criminal record. Note, that we only collect this information where local legal requirements permit.

How we collect the information: From you, in your completed application form.

Why we collect the information (legal basis): To carry out statutory checks with your consent. For reasons of substantial public interest (preventing or detecting unlawful acts, suspicion of terrorist financing or money laundering in the regulated sector and protecting the public against dishonesty). To make an informed recruitment decision (our legitimate interests)

How we use and may share the information: Information shared with DBS and other regulatory authorities as required. Used to make an informed recruitment decision.

The information we collect: Details of your referees.

How we collect the information: From your completed application form.

Why we collect the information (legal basis): Where required, with your consent. To make an informed recruitment decision (our legitimate interests). To enter into/perform a contract with you (the employment contract) and/or to take steps at your request prior to doing so.

How we use and may share the information: To carry out a fair recruitment process. Used to make an informed recruitment decision. Information shared with relevant managers, HR personnel and the referee.

The information we collect: Details about your disability status and health. Note, that we only collect this information where local legal requirements permit.

How we collect the information: From your completed application form, medical questionnaire, interview, or from your directly.

Why we collect the information (legal basis): To comply with our legal obligations to make reasonable adjustments.

How we use and may share the information: To carry out a fair recruitment process. Information shared with relevant managers, HR personnel and the referee.

Part B - Before making a final decision to recruit

The information we collect: Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers (if you provide us with them).

How we collect the information: From your referees (details of whom you will have provided).

Why we collect the information: To make an informed recruitment decision (our legitimate interests).

How we use and may share the information: To enter into/perform a contract with you (the employment contract) and/or to take steps at your request prior to doing so. To obtain the relevant reference about you. Information shared with relevant managers and HR personnel. Used to make an informed recruitment decision.

The information we collect: Information regarding your academic and professional qualifications*.

How we collect the information: From you, or where permissible, from your education provider, from the relevant professional body.

Why we collect the information: To make an informed recruitment decision (our legitimate interests). To enter into/perform a contract with you (the employment contract) and/or to take steps at your request prior to doing so.

How we use and may share the information: Information shared with relevant managers and HR personnel. To carry out a fair recruitment process. Used to make an informed recruitment decision.

The information we collect: Information regarding your criminal record, in criminal records certificates (CRCs, DBS checks and enhanced criminal records certificates (ECRCs)*. Note, that we only collect this information where local legal requirements permit.

How we collect the information: From you and from the Disclosure and Barring Service (DBS).

Why we collect the information: To carry out statutory checks with your consent. For reasons of substantial public interest (preventing or detecting unlawful acts, suspicion of terrorist financing or money laundering in the regulated sector and protecting the public against dishonesty). To comply with our legal obligations.

How we use and may share the information: Used to make an informed recruitment decision. Information shared with DBS and other regulatory authorities as required.

The information we collect: Your nationality and immigration status and information from related documents, such as your passport, driving licence, VISA, national insurance number or other identification and immigration information – to the extent permitted by local law*.

How we collect the information: From you and, where necessary, the Home Office.

Why we collect the information: To comply with our legal obligations.

How we use and may share the information: To carry out right to work checks. Information may be shared with the Home Office.

The information we collect: A copy of your driving licence and relevant driving checks and driving assessment comments – if driving skills are required for the position you are applying*.

How we collect the information: From you.

Why we collect the information: To comply with our legal obligations. Where applicable, to comply with the terms of our insurance (our legitimate interests).

How we use and may share the information: Used to make an informed recruitment decision. To ensure that you have a clean driving licence. Information may be shared with our insurer.

You are required to provide the categories of information marked ‘*’ above to us to enable us to verify your right to work and suitability for the position.