Privacy Notice for Prospective Employees, Employees, Workers, Agency Workers, Contractors, Secondees and Non-Executive Directors

Introduction

Bunzl (which may include Bunzl plc, Bunzl UK Limited (“UK”) or Bunzl Pension Trustees Limited (“Pension Trustees”)) is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you before, during and after your working relationship with us, in accordance with our obligations under data protection legislation. It also covers who we share it with and will also explain what rights you have with regards to your personal data and how you can exercise those rights.

Who does it apply to?

It applies to all current and former employees, workers, agency workers, contractors, secondees and non-executive directors as well as prospective employees during the recruitment process.

For the purposes of the General Data Protection Regulation, Bunzl is the 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.

This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Our registered office address is:

Bunzl plc (Co ref 00358948), UK (Co ref 02902454), and Pension Trustees (Co ref 02775657), York House, 45 Seymour Street, London, W1H 7JT, United Kingdom

Bunzl Ireland Limited (Co ref IE114401), Arthur Cox Building, Earlsfort Terrace, Dublin 2, Ireland

If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at BUKI.GDPR@bunzl.co.uk, contact your local line manager or write to us at the address above. Bunzl plc and Pension Trustees are incorporated in the UK, outside the EU. We have appointed a representative for the purposes of the GDPR compliance, and to deal with any supervisory authorities or data subjects within the EU in this respect.

• We have appointed Bunzl Outsourcing Services B.V. as the Bunzl plc representative
• Bunzl Outsourcing Services BV (Chamber of Commerce 33054904, Establishment No. 000019725086) Rondebeltweg 82 Almere, 1329 BG Netherlands
• We have appointed Bunzl Ireland Limited as the UK and Pension Trustees representative

The kind of information we hold about you

We may collect, store, and use the following categories of personal information about you (please note this list is not exhaustive):

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
• Date of birth and gender
• Marital status and dependants
• Next of kin and emergency contact information
• National Insurance number or equivalent
• Bank account details, payroll records and tax status information
• Salary and other compensation information, annual leave, pension and benefits information
• Start date
• Location of employment or workplace
• Copy of driving licence if relevant
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
• Education history
• Employment records (including job titles, work history, working hours, training records and professional memberships)
• Performance information
• Disciplinary and grievance information
• CCTV footage and other information obtained through electronic means such as swipecard records
• Information about your use of our information and communications systems
• Photographs

We may also collect, store and use the following "special categories" of more sensitive personal information:

• Information about your race or ethnicity, religious beliefs and sexual orientation
• Trade union membership
• Information about your health, including any medical condition, health and sickness records
• Biometric data
• Information about criminal convictions and offences and similar information where required due to the nature of your responsibilities

How we collect and use information about you

How is your personal information collected?

We collect personal information about prospective employees, employees, workers, agency workers, contactors, secondees and non-executive directors through the application and recruitment process, either directly from candidates or sometimes from an employment agency and from our background check provider(s). We may also collect additional information from third parties including former employers, credit reference agencies, the Disclosure and Barring Service and other background check agencies. In some cases this will also involve checking eligibility to work in secure environments through DBS checking as well as driving licence checks if this is a condition of continued employment.

We will collect additional personal information throughout the period of you working for us.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need to perform the contract we have entered into with you
• Where we need to comply with a legal obligation
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• In certain circumstances, through consent. This may also involve explicit consent to pass the data to a third party

Situations in which we will use your personal information

We need all the categories of information in the list above (see The kind of information we hold about you) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The types of situations in which we may process your personal information are listed below (this list is not exhaustive).

• Making a decision about your recruitment or appointment
• Determining the terms on which you work for us
• Checking you are legally entitled to work in the UK or other location
• Administering the contract we have entered into with you
• Paying you and, if you are an employee or non-executive director, deducting tax and National Insurance contributions as well as any other deductions we are obliged to take
• Providing employee benefits to you (for example, health insurance, life insurance, save as you earn, health check-ups, discount schemes and other benefits from time to time)
• Liaising with our pension provider or pension trustees
• Business management and planning, including accounting and auditing
• Conducting performance reviews, managing performance and determining performance requirements
Education, training and development requirements
• Managing sickness absence
• Ascertaining your fitness to work. This may include ongoing criminal convictions checking and legal right to drive
• Making decisions about salary reviews and other compensation
• Assessing qualifications for a particular job or task, including decisions about promotions
• Gathering evidence for possible grievance or disciplinary hearings
• Making decisions about your continued employment or engagement
• Making arrangements for the termination of our working relationship
• Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work
• Complying with health and safety obligations (including the use of CCTV & telematics)
• To prevent fraud
• To monitor your use of our information and communication systems to ensure compliance with our IT policies
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
• To conduct data analytics studies to review and better understand employee retention/attrition rates
• Diversity monitoring
• To comply with our regulatory obligations

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

How we use special categories of more sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

• In limited circumstances, with your explicit consent
• Where we need to carry out our legal obligations and in line with our data protection policy
• Where it is needed in the public interest, such as for equal opportunities monitoring and in line with our data protection policy
• Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards

We may also when required, process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations as an employer

We will use your special categories of more sensitive personal information in the following ways:

• We will use information relating to leaves of absence, which may include sickness absence or family related leave, to comply with employment and other laws
• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits
• We will use information about your race or national or ethnic origin, religious beliefs and disability or long-term health condition to ensure meaningful diversity monitoring and reporting
• We will use trade union membership to comply with employment law or other legal obligations
• We may be aware of your sexual orientation if you provide us with details of your marital status or your partner’s details (for example, next of kin information). However, sexual orientation information is not separately recorded or monitored
• Some of our IT facilities use biometric data (fingerprints) for systems access or time reporting

Information about Criminal Convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Where appropriate, we will use information about criminal convictions and offences to determine whether you are suitable for continued employment with Bunzl and to determine whether you are suitable for particular roles within Bunzl. In some circumstances, we are required to pass this to a third party as part of security requirements e.g. working in secure environments such as airports and government buildings.

Automated decision making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

Data sharing, security and retention

Will my data be shared with anyone else?

We may share your data with third parties, including other companies within the Bunzl Group and third-party service providers (including contractors and designated agents) where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. The following example activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services and audits.

Sharing your personal information will be done on a ‘need to know’ basis and only where it is necessary to do so or where we are required to share information. We may share personal information when we buy or sell any business or assets. We aim to put the necessary safeguards in place to ensure that personal information that we are legally responsible for remains properly protected and is used appropriately when in the hands of a third party.

We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.

Sometimes we may need to send your personal information overseas or outside of the EU, for example if you move to an overseas Bunzl business. If we do, you can expect a similar degree of protection in respect of your personal information. When we do this, we aim to put the necessary safeguards in place to ensure that your personal information remains properly protected and is used appropriately wherever it is located geographically. This will usually be achieved by contractual means.

The personal information we have collected from you will be shared with certain organisations who will use it to prevent fraud, other unlawful or dishonest conduct, malpractice, and other seriously improper conduct. If any of these are detected you could be refused certain services or employment. Your personal information will also be used to verify your identity.

How secure is my data?

We have put in place measures to protect your information, including appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those individuals, agents, contractors and other third parties who have a business need to know.

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.

How long will you retain and use my information for?

We aim to keep your information for only as long as is necessary for our business needs and in compliance with any legal or regulatory duties to retain it for a particular period, e.g. satisfying any legal, accounting, regulatory or reporting requirements. However long we retain personal information for, we will make sure it is protected properly and used responsibly.

Details of retention periods for different aspects of your personal information are available in our data retention policy.

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.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker, agency worker, contractor, secondee or non-executive director of the company we will retain and/or securely destroy your personal information in accordance with our data retention policy.

Rights of access, correction, erasure, restriction/objection, transfer and intervention

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. You can update some of your details directly in My View. For all other updates, please email us at HR.Support@Bunzl.co.uk.

Your rights in connection with personal information

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. This may also include having it transferred to another organisation
• 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)
• 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. You also have the right to object where we are processing your personal information for direct marketing purposes
• 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
• Right to human intervention If the personal data is being used to make automated decisions about you as the data subject (e.g. profiling), to be told what logic the system uses to make those decisions and to be able to request human intervention to override any such automated decisions

If you make a request, we have one month to respond to you.

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 us.

We will always give you the rights that you are legally entitled to but the rights set out above are qualified rights. Any requests will be assessed on a case-by-case basis. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 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.

Right to withdraw consent

In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Do you have to provide your personal information to us?

You will never be required to provide personal information to us but we cannot employ you unless we keep the records we need. We will only collect the information that is necessary to employ you and will keep it secure and will use it responsibly and fairly at all times. Please contact us if you have any concerns about this.

Do we use automated decision-making?

We may carry out automated decision-making when you use our website. This involves providing content to you based on your online behaviour. This allows us to display content that is relevant to you. We may also use other electronic tools such as automated CV scanning or test scoring when employees are being recruited.

Do we use your personal information for marketing?

We do not use your personal information obtained for employment purposes to carry out direct marketing in general but we may use the information we hold in order to communicate with you about your employment and to keep you informed about matters concerning Bunzl and/or the business you work for. This may therefore include special offers, product discounts and other benefits as a result of you being a Bunzl employee that we wish to make available to you.

Do we use cookies?

We use cookies to make our website work properly – including for recruitment and employment purposes, to monitor its usage and to display content that we believe will be relevant to the people who visit our sites. If you register with us or if you continue to use our site then you agree to our use of cookies. Our external websites have a cookie control that allows you to review and change the cookie settings.

You can also block cookies by adjusting your browser settings. However, if you choose to block all cookies you may not be able to access all, or parts, of our site and some features will not work properly.

Data Privacy Officer

We have appointed a data protection privacy champion 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 us or your line manager. If you have any concerns about our use of your personal information, you can make a complaint to us. You can also complain to the ICO/DPC if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113   ICO website: https://ico.org.uk/global/contact-us/

The DPC’s address:

Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

Helpline number: 076 110 4800   DPC website: https://www.dataprotection.ie/en/contact/how-contact-us

Changes to this privacy notice

We reserve the right to update this privacy notice at any time; this privacy notice was updated March 2023.