Privacy Notice - Recruitment

What is the purpose of this document? 

We are committed to protecting, safeguarding, and respecting your privacy. 

This privacy notice references “we”, “us” and “our” which means Essar Oil UK Limited (trading as “EET Fuels”) and its group of subsidiary companies (referred to as the “group” below).   

This privacy notice describes how we collect and use personal information about you during and after engaging with us in relation to any job recruitment activities.  

We are a data "controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. 

Who does it apply to? 

This privacy notice applies to individuals who apply to work for, or who attend a recruitment event, or undertake an assessment with us. This includes prospective employees, interns, and contractors. 

Data protection principles 

We will comply with data protection law, which says that the personal information we hold about you must be: 

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely in a manner to ensure appropriate security of the personal data including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage
7. We as the controller shall be responsible for and be able to demonstrate compliance with the Data protection Principles. 

 The kind of information we hold about you 

We may collect, store and use the following categories of personal information about you: 

• Personal contact information. 

• Date of birth. 

• Whether you have the legal right to work in the country in which you have applied. 

• Your application for employment or CV,  

• Your qualifications and experience. 

• Results of interviews and assessments. 

For the purposes of recruitment, special categories of data (‘sensitive personal data’) including health data may be processed. 

We may also gather additional sensitive personal data regarding applicants, including nationality, racial and/or ethnic origin. 

The Purposes for which we process your personal data 

We process your personal data for the following purposes: 

• Human Resources, personnel management, business process execution and internal management - including resource planning, and recruitment. 

• Health, safety and security - including protection of an individual’s life or health, occupational health and safety, assessing eligibility and fitness to work, protection of Essar’s assets and staff, authentication of individual status and access rights, making provisions in the workplace. 

• Legal and/or regulatory compliance - including compliance with legal or regulatory requirements;  

• Management reporting and analysis - including statistical analysis and surveys regarding the quality of the recruitment process; 

• Where it is necessary for our legitimate business interests (such as ensuring compliance with legal obligations other than those related to employment or social security, the protection of Essar assets, reputation and Essar employees and contractors) except where such interests are overridden by the interests or fundamental rights and freedoms of the applicant;  

• We may also process your personal data for a secondary purpose where it is closely related, such as: 

• storing, deleting or anonymising your personal data; 

• fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defence of claims;  

Pre-screening of Applicants 

We carry out screening of all Applicants who we intend to make an offer of employment, engagement or internship (as the case may be) and prior to any offer being confirmed for the purposes of: 

• verifying the information that an applicant provides during the screening/interview process. This will include verifying information with current/previous employers and educational institutions. No steps will be taken in this respect until the applicant confirms the verification can take place. 

Why do we process your personal data? 

We only process personal data of Applicants: 

• in order to take steps at the request of the applicant prior to entering into a contract. 

• where it is necessary to comply with a legal obligation to which the relevant Essar Group company/companies is subject to ensure compliance with applicable employment, tax and social security laws and regulations. 

• where it is necessary for the legitimate business interests of Essar (such as ensuring compliance with legal obligations other than those related to employment or social security, the protection of Essar assets, reputation and Essar employees and contractors) except where such interests are overridden by the interests or fundamental rights and freedoms of the Applicant; or 

• (only if legally required) with the explicit consent of the Applicant. 

 Who will we share the personal data with? 

Your personal data is processed for the purposes referred to above and will only be shared on a strict need-to-know basis with: 

• Other companies within the Essar group of companies, including to those which may be located outside of your location and/or the Economic European Area (‘EEA’). 

• Authorised third-party agents, service providers, external auditors and/or subcontractors of Essar in particular authorised third parties who carry out reference and background checks on behalf of Essar. 

• A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant Essar company/companies is subject or as permitted by applicable law. 

Transfers of your personal data to other countries 

Where your personal data is transferred to companies within the Essar Group and/or to third parties located outside of your country (including outside of the European Economic Area and the UK) we take organisational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data.  

Data Security 

We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate. 

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. Additionally, 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 they are subject to a duty of confidentiality.  

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. 

Data retention 

We hold the personal data of unsuccessful Applicants for at least 6 months but no longer than two years after the recruitment process or assessment has been completed. 

Information may be held for a longer period where there is a legal or regulatory requirement (in which case it will be deleted once no longer required for the legal or regulatory purpose). 

If you are successful in your application, the personal data gathered through the recruitment process will be retained in line with the Privacy Notice uploaded on the Intranet portal for - Employees and Dependants’ Personal Data. 

Your rights in relation to your personal data 

Under certain circumstances, by law you have the right 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 there is no good reason for us continuing to process it.  

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.  

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DPO in writing. 

Please contact DPO@eetfuels.com  

Data Protection Officer ( DPO ) 

We have appointed a DPO to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You can do this by email via DPO@eetfuels.com or in writing to Essar Oil (UK) Limited, 5th Floor, The Administration Building, Stanlow Manufacturing Complex, Ellesmere Port, Cheshire, CH65 4HB United Kingdom. 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) with respect to data protection issues.  

Contact details  

Information Commissioner's Office 

Wycliffe House Water Lane 

Wilmslow Cheshire United Kingdom 

SK9 5AF Website: www.ico.org.uk Phone: 0303 123 1113 (local rate) or 01625 545 745 (national rate) 

 Changes to this Privacy Notice 

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.  

If you have any questions about this privacy notice, please contact the DPO by sending an email to DPO@eetfuels.com.