Aldi Stores Limited Candidate Recruitment Privacy Notice

KEY PRINCIPLES

Your personal data is important. So important that there are a range of laws in place to safeguard it (the most important of which is the General Data Protection Regulation or “GDPR”). ALDI is committed to doing its part to protect your personal data and comply with those laws.

In practice, this means that all personal data which we hold about you 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.

This Privacy Notice is broken down into a number of sections to allow you to more easily find out more about how we use your personal data and the steps we take to protect it.

1. OVERVIEW OF THIS NOTICE AND WHO WE ARE

Purpose of this Privacy Notice

This Privacy Notice sets out how ALDI collects and processes your personal data as a recruitment candidate. This covers the use of our Site, but also includes any other elements of the ALDI recruitment process, from sending in your CV, to having interviews, to becoming an ALDI employee.
By visiting https://www.aldirecruitment.co.uk/ (our “Site”), or otherwise submitting your personal data to us as part of an application, you are accepting and consenting to the practices described in this Privacy Notice.

It is important that you read this Privacy Notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.

Please note that this policy does not relate to the collection of your data as a customer of ALDI, except insofar as it relates to the use of cookies by ALDI UK and Ireland, please see Section 6 (Cookies Notice) for further details. Details relating to the collection of your data as a customer of ALDI and relating to the use of cookies. These details can be found in the ALDI Customer Privacy Notice

Finally, our Site is not intended for children and we do not knowingly collect data relating to children.

Who we are

We are ALDI Stores Limited (collectively referred to as "ALDI", "we", "us" or "our" in this Privacy Notice). We are registered in England & Wales under registration number 02321869. Our registered address is Holly Lane, Atherstone, Warwickshire, CV9 2SQ. Our VAT number is GB813053468. Our Data Controller Registration Number is Z5724527.

Contact details

We welcome questions and comments regarding this Privacy Notice or our use of your data. If you would like to contact us please use the details below or any relevant links provided on our Site.

We have a Data Privacy Team responsible for overseeing questions in relation to this Privacy Notice and our use of your data. Their details are set out below:

Email address: privacy@aldi.co.uk

Postal address: Holly Lane, Atherstone, Warwickshire, CV9 2SQ

Privacy complaints procedure

You always have the right to make a complaint to the Information Commissioner's Office (“ICO”) if you think your data is being misused. The ICO is the UK’s supervisory authority for data protection issues (www.ico.org.uk).

We always appreciate the chance to try to deal with any data protection concerns before they are referred to the ICO so, if you are happy to do so, please do not hesitate to contact us using the details above so that we can try to help you out in the first instance.

Changes to this Privacy Notice

This Privacy Notice was last updated on 18th June 2020.

Any changes we may make to our Privacy Notice in the future will be posted on this page. We recommend that you check this page from time to time to take notice of any changes we make, as they are binding on you if you provide us with information after such a change has been made.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details set out in the “Contact Details” section:

If you are experiencing technical issues with the website please contact our Technical Support team at aldisupport@vacancyfiller.co.uk

For any recruitment enquiries please contact our dedicated careers team at recruitment@aldi.co.uk

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Informing us of changes to your data

It is important that the personal data we hold about you is accurate and current. As such you can use your online ‘Candidate Portal’ account to amend a number of the details which we hold about you. For example, if you change your contact number or email address, you can click on the ‘edit’ button and your old contact information will be removed from your account.

Third-party links

Our Site may contain links to and from third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. Please check the relevant third-party privacy notices before you submit any personal data to them.

Governing Law and Jurisdiction

This Privacy Notice is governed by English law and you can bring legal proceedings in respect of it in the English courts. If you live in Scotland you can bring legal proceedings in respect of it in either the Scottish or the English courts. If you live in Northern Ireland you can bring legal proceedings in respect of it in either the Northern Irish or the English courts.

2. THE DATA WE COLLECT ABOUT YOU

“Personal data” means any information about an individual from which that person can be identified. It does not include data where the identity of the person concerned has been removed (which is called “Anonymised Data”).

We may collect, use, store and transfer different kinds of personal data about you. This can be broken down into the following categories:

• Identity Data includes your name, username or similar identifier, marital status, title, date of birth, personal financial details, and gender (this will primarily be text based, but could also include audio, photos, videos and other forms of media).
• Employment and Qualification Data includes details of your employment history, details of your qualifications and the results of tests and interviews you complete during the recruitment process.
• Contact Data includes your address, email address and telephone numbers.
• Financial Data includes bank account information. This data is captured only after a conditional job offer has been issued and is stored for a temporary period of 12 weeks until the data is transferred into the Payroll system.
• Technical Data includes the internet protocol (IP) address of your device, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site.
• Profile Data includes your username and password, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Site.

We also collect, use and share “Aggregated Data” for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not reveal your identity. For example, we may aggregate our users’ Usage Data to calculate the percentage of those users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

Special Category Data: We may also collect, store and use the following types of more sensitive personal information:

• information about your race and ethnicity;
• information about your health, including any medical condition; and
• where we are legally allowed to do so, information about criminal convictions and offences.

If you fail to provide personal data

If you fail to provide information when requested, which is necessary for us to process your application (such as evidence of qualifications or work history), we will not be able to consider your application and it will be rejected.

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including:

• Direct interactions. You may give us personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes:
  • Information that you provide to us in a curriculum vitae, covering letter or similar document;
  • Information that you provide by filling in forms on our Site;
  • Information that you provide to us during an interview: This may include interviews both in-person by phone, video or internet. Interviews may be recorded for training and quality purposes;
  • Assessment Results: Some of our recruitment processes include one or more assessments, the results of which will be collected and used to assess your application;
  • Troubleshooting details: Information that you provide when you report a problem with our Site or processes; and/or
  • Contact details: Information that you provide when contacting the Careers Team or otherwise corresponding with us.
• Third-parties or publicly available sources. We may receive data from various third-parties and public sources such as:
  • Recruitment Agencies;
  • Someone you know referring you for a role;
  • Background Check Providers;
  • The Disclosure and Barring Service and Disclosure Scotland; and
  • Your named referees.
• Automated technologies or interactions. We may also collect and process the following data automatically when you use our Site:
  • the internet protocol (IP) address of your device, your login information, details of the type of device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of your device's wireless network interface, or the mobile phone number used by your device), mobile network information, your browser type and version, your time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time), page response times, download errors and bugs, the length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the Site and any phone number used to call the Careers Team;
  • information stored on your device which you consent to share with us (such as contact information, friend lists, login information, photos, videos or other digital content);
  • any details of your current location which you consent to share with us; and
  • information provided to us by third-parties (including, for example, business partners, sub-contractors in technical, analytics providers, search information providers and credit reference agencies).
• Cookies: We may also receive Technical Data about you if you visit other websites employing our cookies, please see Section 6 (Cookies Notice) for further details.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where:

• we need to perform the contract we are about to enter into or have entered into with you;
• it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests;
• we need to comply with a legal or regulatory obligation; and/or
• you have specifically consented to us using your personal data in a particular way.

Set out below is a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Please note that we may:

• process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data;
• combine information from other sources with information you give to us and that which we collect about you; and
• use this combined information for the purposes set out below.

Activity

1. Managing the recruitment process: This may include:

1. processing your information to decide whether you meet the basic requirements to be shortlisted for a role;
2. processing your information to determine whether you have a legal right to work for us;
3. circulating and subsequently processing online assessments (which may include personality tests);
4. if you pass our initial assessment, inviting you for an interview (which may be conducted in person or by phone, video or over the internet);
5. assessing your information and the results of any interview (and comparing it to other applications we have received); and
6. communicating with you about the recruitment process.

Automated decision-making: Our recruitment processes may include the use of automated decision-making procedures. See Section 6 of this Notice (Automated decision-making) for further details.

Types of Data: This will require us to use your: (a) Identity; (b) Employment and Qualification Data; (c) Contact Data; (d) Profile Data; and (e) Usage Data.

Basis for processing: This processing is both necessary for us to comply with our legal obligations and in accordance with our legitimate interests (to ensure that our recruitment practices help us attract and retain the best employees).

Third-Parties Involved: We use Recruitment Agencies, who provide us with details of prospective candidates, as well as selected third-parties involved with:

1. online platform providers for our testing and recruitment processes;
2. application screening (which may include the use of third-parties who are recruitment specialists in different sectors, such as logistics);
3. the completion of background checks; and
4. conducting interviews.

2. Carrying out background and reference checks, where applicable: This may include criminal background checks as well as checking education qualifications and employment history.

Types of Data: This will require us to use your: (a) Identity; (b) Employment and Qualification Data; and (c) Contact Data.

Basis for processing: This processing is both necessary for us to comply with our legal obligations and in accordance with our legitimate interests (to ensure that our recruitment practices help us attract and retain the best employees).

Third-Parties Involved: Selected third-parties involved with the completion of such background checks (including the Disclosure and Barring Service and Disclosure Scotland). Any third-parties which you specify as referees.

3. Processing information about criminal convictions: We may process information about criminal convictions if we consider it necessary for the role or are otherwise legally required to carry out such checks. This will be assessed on a role-by-role basis. More detailed checks may be required for those roles which involve a high degree of trust, such as those involving the handling or transfer of significant amounts of money.

Types of Data: This will require us to use your: (a) Identity; (b) Contact Data and (c) “Special Category” Data.

Basis for processing: This processing is necessary for us to comply with our legal obligations and in accordance with our legitimate interests (to ensure that our recruitment practices help us attract and retain the best employees).

Third-Parties Involved: Selected third-parties involved with the completion of such criminal conviction checks (including the Disclosure and Barring Service and Disclosure Scotland).

4. Processing other sensitive “Special Category Data”: We may use your special category data to:

1. consider whether we need to provide appropriate adjustments during the recruitment process, for example whether reasonable adjustments need to be made: (i) during a test or interview; or (ii) to the role itself;
2. contact you to discuss any such adjustments; and/or
3. ensure meaningful equal opportunity monitoring and reporting.

Types of Data: This will require us to use your: (a) Identity; (b) Contact; and (c) “Special Category” Data.

Basis for processing: This processing is both necessary for us to comply with our legal obligations. We may also process such data on an anonymised basis, so that it cannot be linked back to you.

Third-Parties Involved: Selected third-parties involved with making the adjustments referred to above. You may be contacted directly by such third-parties to discuss the scope of those adjustments.

5. Data Analytics: To use data analytics to improve our Site and recruitment process.

Types of Data: This will require us to use your: (a) Technical; and (b) Usage data.

Basis for processing: This processing is in accordance with our legitimate interests (to keep our Site updated and to develop our recruitment processes).

Third-Parties Involved: Selected third-parties involved with:

1. the development of our Site; and
2. the development of our recruitment processes.
3. data analytics.

6. Managing our relationship: To manage our relationship with you, which will include:

1. registering you as a user of our Site;
2. managing feedback in respect of our recruitment process (including dealing with any queries or complaints);
3. providing you with the information that you request from us; and
4. keeping records of our relationship and recruitment practices.

Types of Data: This will require us to use your: (a) Identity; (b) Employment and Qualification Data; (c) Contact Data; (d) Profile Data; (e) Technical Data; and (f) Usage Data.

Basis for processing: This processing is: (a) necessary for the performance of a contract with you; (b) necessary to comply with our legal obligations; and (c) in accordance with our legitimate interests (to keep our Site updated, to develop our recruitment processes and to keep our records updated).

Third-Parties Involved: Selected third-parties involved with managing and developing our recruitment processes.

7. Business Administration and Security: To administer and protect our business, and the Site, which will include:

1. improving our Site to ensure that content is presented in the most effective manner for you and for your device;
2. allowing you to participate in interactive features of our Site, when you choose to do so;
3. troubleshooting and system administration;
4. data analysis and research;
5. testing and system maintenance;
6. usability assessment and improvement;
7. accessibility assessment and improvement;
8. technical support and reporting; and
9. hosting of data.

Types of Data: This will require us to use your: (a) Identity; (b) Employment and Qualification Data; (c) Contact Data; (d) Technical Data; (e) Profile Data; (f) Usage Data; and (g) “Special Category” Data.

Basis for processing: This processing is both necessary for us to comply with our legal obligations and in accordance with our legitimate interests (for running our business, the provision of administration and IT services, managing our network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

Third-Parties Involved: Selected third-parties involved with:

1. the development of our Site;
2. the development of our recruitment processes; and
3. the encryption of data.

5. AUTOMATED DECISION-MAKING

Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. We may, for example, use automated decision-making processes to automatically reject candidates who do not have the qualifications or grades we require for a role; or who do not obtain a minimum score on a test completed as part of the recruitment process.

If you have any questions or concerns regarding automated decision-making please contact us using the details set out in the “Contact Details” section:

If you are experiencing technical issues with the website please contact our Technical Support team on 0844 800 9386 or email aldisupport@vacancyfiller.co.uk

For any recruitment enquiries please contact our dedicated careers team on 0800 042 0800 or email recruitment@aldi.co.uk

This includes if you want to have a decision re-reviewed by a human, make your case as to why an automated decision was incorrect, or otherwise contest such a decision.

6. COOKIES NOTICE

What are cookies

Cookies are small pieces of information that are stored on the hard drive of your device and they enable a server to collect information from an internet browser. You can find out more about how cookies work at www.aboutcookies.org.

How we use cookies

We use cookies to:

• personalise our Site to you. For example, to try and ensure that language and region displays are correctly configured for you;
• improve our Site. For example, knowing how our users navigate our Site and use its features allows us to streamline the user experience, speed up searches, identify bugs, make enhancements and ultimately get you to the right page and product faster;
• estimate our audience size and usage pattern;
• provide faster and more personal service by collecting information in respect of any accounts which you have on our Site;
• collect Anonymised Data about the websites from which users have travelled to our Site;
• store information about any preferences which you set, so we can do things like greet you personally and speed up your log-in when you come back to our Site;
• identify which of your device(s) you use to access our Site or any account which you have registered on it; and prevent credit fraud and various forms of cyber-crime.

The cookies we use

• may persist on your device between visits to our Site, so that, for example, we can identify you when you visit again; and
• may be provided either by us or by third-party service providers (such as analytics and search engine providers).

Click here to view the cookies we use.

Avoiding Cookies

You can set your browser to accept or reject certain cookies or, if you prefer, you can set your browser to alert you each time a cookie is detected. Previous cookies that have been stored on your device can also be deleted. However, if you block our cookies or you subsequently delete a cookie that has been placed on your device, it will not be possible for you to use our Site effectively as our systems rely on cookies to identify you as the user.

7. DISCLOSURES OF YOUR PERSONAL DATA

Disclosure of your personal data

First and foremost, you can rest assured that your personal data will not be shared with third-parties unnecessarily. We may disclose your personal data for the purposes set out in this Privacy Notice:

• if the possibility of such disclosure is otherwise stated in this Privacy Notice or otherwise when the personal data is collected from you;
• in particular, to the specific third-parties described in Section 4 (How we use your personal data);
• to other companies in the ALDI Group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006). This includes ALDI Stores (Ireland) Limited, registered in Ireland under registration number 294035, whose registered address is at 67-68 Fitzwilliam Square, Dublin 2 D02 R284;
• to service providers acting as processors or joint controllers who provide us with IT and system administration services;
• to professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide us with consultancy, banking, legal, insurance and accounting services;
• to HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect our rights, property, or safety, or the rights, property or safety of our customers, or others. This includes exchanging information with: (a) the police or other investigatory or law enforcement authorities; and (b) companies and organisations involved in fraud protection and credit risk reduction; and/or
• to third-parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. Unless specifically stated in this Privacy Notice, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Disclosure of Anonymised Data or Aggregated Data

We may also share Anonymised Data or Aggregated Data to third-parties such as analytics and search engine providers that assist us in the improvement and optimisation of our Site.

This Anonymised Data will be collected using cookies in a way which alone cannot identify any individual.

8. INTERNATIONAL TRANSFERS

The data that we collect from you will be stored on secure servers within the European Economic Area ("EEA") The majority of such data is held within the UK.

Certain information may be accessed and processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of background checks and support services.

We may also share your personal data within the ALDI Group (as defined above). This may also involve transferring your data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• the transfer will be to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission;
• we will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
• where we use providers based in the US, we may transfer data to them if they are part of the “Privacy Shield” scheme. This scheme requires them to provide similar protection to personal data shared between the Europe and the USA.

9. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

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

Please note that, notwithstanding the steps we take, the transmission of information via the internet can never be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site.

10. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If your application is successful and you become an employee of ALDI then your data will form part of your employment record and be processed and stored in accordance with the ALDI Employee Privacy Notice (which will be made available to you when you become an ALDI employee).

If your application is not successful your details will be deleted following a period of 12 months inactivity. 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 process in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with the applicable laws and regulations.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such data without further notice to you.

11. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us using the details set out in the “Contact Details” section:

If you are experiencing technical issues with the website please contact our Technical Support team on 0844 800 9386 or email aldisupport@vacancyfiller.co.uk

For any recruitment enquiries please contact our dedicated careers team on 0800 042 0800 or email recruitment@aldi.co.uk

A summary of the rights you have is set out below:

• Data Subject Access Requests: You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Correction: You have the right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Erasure: You have the right to request we erase your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Processing Objection: You have the right to object to us processing your personal data 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 as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Processing Restriction: You have the right to request we restrict the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Data Transfer: You have the right to request we transfer your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdrawing consent: You have the right to withdraw your consent to processing where we are relying on that consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent in this way we will no longer be able to process your application.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.