Data Privacy notice
Thank you for visiting the Imperial Brands’ Global Careers website and for your interest in Imperial’s career opportunities.
This notice, our “Privacy Notice”, explains what personal information we collect about you online and offline in our recruitment process and how we use and share that information. We encourage you to review our Privacy Notice carefully before applying for any of our jobs.
This Privacy Notice was last updated on 21st January 2022.
It applies to all applicants applying for global positions with Imperial Brands’ companies through this Global Careers website.
If you have any questions about how we handle or protect your personal information, please contact us using the contact details below.
In addition to the commitments set out in this Privacy Notice, Imperial Brands has a set of data privacy rules which
apply to the processing of all personal information by our organisation. These privacy rules can be found at https://www.imperialbrandsplc.com/content/dam/imperial-brands/corporate/about-us/governance/code-conduct-2021/English%20Code%20of%20Conduct.pdf
Who we are
We are Imperial Tobacco Limited, 121 Winterstoke Road, Bristol, BS3 2LL in the United Kingdom. We are responsible for operating these online career services for the Imperial Brands group of companies.
How we collect personal information
We collect your personal information to provide you with a seamless recruitment process. We collect information from you when you register your user profile and apply for a job with us. We collect some information about you automatically, such as information collected by cookies, when you use, access or interact with us via our recruitment site. Some of the information we collect about you comes from third-parties such as analytics service providers or, depending on your “settings”, social media providers.
Information we collect
We collect personal information in our drive to recruit skilled and talented people to join our teams.
Personal information is any information that tells us something about you.
- We collect the following kinds of personal information:
- Contact details (address, email, phone numbers)
- Date of birth
- Employment history
- Information from your CV
- Information generated as part of the recruitment process, such as interview notes, right to
work documentation, qualifications and references
- IP address, location data and other information generated by your use of our website
We ask you to let us know about any disability for which you need us to make reasonable adjustments during the recruitment process. By submitting this information in your application, you are giving your consent to our use of this information to make reasonable adjustments for you where necessary. You may withdraw your consent at any time. If we do not have your consent, or if you do not provide the information to us, we may not be able to provide you with the reasonable adjustments you need.
Where it is a legal requirement in your country, we will ask you for the demographic information we need to comply with the law. We may also ask you if you would let us use this information on an anonymous basis as part of our ongoing efforts to ensure our recruitment processes are inclusive.
You can choose to use your LinkedIn profile on our careers website. If you do, you will be asked to allow Imperial access to your account information. This includes the telephone number and email address associated with your LinkedIn account as well as your experience, education, skills and recommendations. Please note that this is a once only import and you will need to ensure the ongoing accuracy of your personal information in your Imperial user profile. During any subsequent application you will have the opportunity to update your information using your LinkedIn profile again. You can disconnect your LinkedIn account from our site at any time from your “settings” in LinkedIn.
Additional information collected if your application is successful
Should you be successful in your application, and where the laws in your country allow it, we will conduct background checks using a third-party service-provider. Background checks involve searches against criminal records, court records and checks related to credit-worthiness or credit standing. The service-provider we use varies according to your location. You will be asked to complete a “Declaration of Consent” which explains what information is collected.
At this stage, we will also contact the references you provide to us from your previous employers.
We will use the information gathered from the background checks and from references to decide whether or not to confirm an offer of employment with Imperial.
The purposes for which we collect your personal information
- Your registration on our recruitment site is voluntary but it is necessary in order to provide you with all the services listed below. Your user profile holds your personal information as well as your choices and preferences in the context of our services:
- Specifying job searches
- Providing you with job search results via email
- Administering your job applications (speculative or for particular vacancies)
- Assessing and making decisions in relation to your suitability for employment with Imperial
- Sending you invitations for video and physical interviews and assessments
- Corresponding with you about your job application, interviews and the outcome of your application
Please keep your profile and personal information you have submitted up to date.
Our recruitment site is capable of making job recommendations based on your viewing habits and, if you agree, our recruiters may contact you in connection with future recruitment opportunities.
What is the legal basis that permits us to use your personal information?
- If you are based in the UK or a European country where the EU rules on data protection apply, we need to tell you the legal basis on which we process your personal information as we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your personal information for recruitment related purposes:
- where we need your personal information to enter into a contract with you (for example, where we consider your application and offer you a role with us);
- where we need to comply with a legal obligation; and/or
- 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.
Some personal information is classified as “special” under data protection legislation. This includes information relating to health, racial or ethnic origin, religious or philosophical beliefs, political opinions, genetic and biometric data, sex life, sexual orientation and trade union membership. This personal information is more sensitive and we need to have further justifications for collecting, storing and using it. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data. We may process these special categories of personal information in limited circumstances with your explicit consent, in which case we will explain the purpose for which the personal information will be used at the point where we ask for your consent.
The table below provides more detail about the personal information we use and the legal basis that we rely on in each case.
• Purpose: Recruitment decisions
Personal information used: Contact details, recruitment information (such as CV, information provided in a cover letter, references), employment records.
Legal basis: Performance of contract and legitimate interests. It is in our legitimate interest to evaluate whether you have the necessary skills and qualities to perform the relevant role.
• Purpose: Right to work checks
Personal information used: Information relating to your right to work status, identification information depending on which country your role is in (for example, in the UK, national insurance number), passport number, nationality, tax status information and contact details
Legal basis: Performance of contract and legitimate interests. It is in our legitimate interest to ensure that those who work for us have the right to work in their relevant location.
• Purpose: Fraud and crime prevention
Personal information used: Information about criminal convictions and offences committed by you. Identify verification information.
Legal basis: Compliance with laws, public interest and legitimate interest. It is in our interests as well as the interest of our candidates/employees to ensure the prevention of fraud and crime is monitored. This helps create a safe workplace for all.
• Purpose: Diversity monitoring
Personal information used: Gender, marital status and dependents and information about your race or ethnicity, religious beliefs, health and sexual orientation.
Legal basis: Compliance with laws or legitimate interest.
• Purpose: To deal with legal disputes
Personal information used: Contact details, references, information submitted as part of the selection process and interview notes.
Legal basis: Legitimate interests. It is in our legitimate interest to process personal information to make and defend legal claims in order to ensure our legal rights are protected.
• Purpose: Candidate relationship
Personal information used: Contact details, web pages you view and whether you interact with the content on the site, list of active devices, associated IP addresses, contents of forms submitted, files containing CVs.
Legal basis: Consent. We rely on your explicit consent to receiving any job search emails from us and contacting you with any further recruitment opportunities.
• Purpose: Data analytics
Personal information used: Device IP address, web pages you view and whether you interact with the content on the site, contents of forms submitted, files containing CVs.
Legal basis: Legitimate interests. It is in our legitimate interest to evaluate our website and its services to ensure its effectiveness. Where possible, we use this data in aggregated non-identifiable form. Where necessary, we get consent.
What happens if you do not provide the personal information that we request?
We need some of your personal information in order to conduct the recruitment and selection process or to alert you to job recommendations as part of our candidate relationship management service. If you do not provide the personal information, we may not be able to continue with the recruitment process and offer you employment/engagement, or we may not be able to alert you to jobs that might be of interest. We explain when this is the case at the point where we collect personal information from you.
Who we share your personal information with
Through our recruitment team, we will use your personal information solely to provide you with the services set out above and to manage any applications you submit.
As part of the process, we share the personal information supporting your application with the relevant Imperial Brands department or function that advertised the role.
We are assisted by the following global service providers:
- Lumesse: providing the recruitment system that processes job applications and hosts your
personal information, making it available to our recruitment team;
- Cielo: recruitment partner administering the end to end recruitment process, including
candidate relationship management and recruitment marketing.
In addition to our global service providers, we may use local service providers to help us with our recruitment processes.
How we look after your personal information
Transmission of information via the internet is not always secure. We cannot guarantee the security of the information while it is being transmitted to our site; any transmission is at your own risk. However, once we have received your information, we take appropriate security measures to prevent unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss of your personal information once it is under our control. We monitor compliance with our policies and take disciplinary action where appropriate. Where we use service providers, we require them to take appropriate security measures to protect your personal information.
Imperial is a global organisation and our vacancies arise all over the world. We will pass your information to the part of the organisation with the job vacancy you have applied for where it will be used to consider your application. In some cases this will be outside of the UK/EEA.
Any personal information you submit via this careers site will be transmitted to Imperial’s global recruitment system and shared with Imperial’s global recruitment services providers.
The recruitment system is provided by Lumesse, which hosts your information on servers in the EU. Our global recruitment partner, Cielo, operates in the country of the Imperial company with the vacancy you have applied for. For the purpose of supporting our recruitment processes, Cielo leverages Clinch, a Candidate Relationship Management system , which hosts data from within the EU. This forms part of Cielo’s TalentCloud a digital eco- system known as TalentCloud which is a range of technologies enabling recruitment processes’ automation such as digital interview scheduling. This information also hosts data and is supported from within the EU.
As rewuired by EU and other countries’ laws, robust service contracts have been put in place to ensure your personal information is adequately secured and handled in accordance with the UK’s and EU’s strict data protection requirements as well as Imperial’s instructions. A copy of the relevant data privacy clauses agreed with our service providers are available on request by contacting us using the details below.
Transfers within the Imperial Brands group of personal data originating in the UK or EU are governed by internal data processing agreements.
How long we hold it for
We will keep your user profile and (if any) application data for as long as legally required in a particular country. If your application is successful and you are hired by an Imperial Brands company, your personal information collected during the recruitment process will be used to form the basis of your employment record and retained for the duration of your employment.
When your information is no longer needed in our recruitment systems (for example, because you are no longer maintaining your user profile), unless there is a legal reason to keep it, your information will be kept for a maximum of 12 months from the date the record was last modified when it will be irretrievably anonymised. If you wish to make an application for a role at Imperial after this time, you will need to set up a new user profile.
If we get your details via a third party (for example, if your settings allow LinkedIn to alert us to you), but you do not wish to take things further with us, we will irretrievably anonymise your personal information within 7 days.
There will be some circumstances where we have statutory obligations to keep your personal information for a longer period or where it is necessary in case of a legal claim. If this is the case, you will be informed accordingly.
You can access and change/delete your user profile content at any time and may also request that your entire user profile be deleted from our database. Your “My Settings” page also gives you the chance to anonymise yourself.
Your information rights
You have the right, within certain legal parameters, to:
- be informed about how we use your personal information;
- obtain access to your personal information that we hold in machine readable format;
- request that your personal information is corrected if you believe it is incorrect, incomplete or
inaccurate (or you can update it yourself in “My Settings”);
- ask us to erase your personal information in certain circumstances;
- ask us to restrict our information processing activities in certain circumstances;
- ask us for a copy of certain personal information that you have provided to us in a commonly
used electronic format;
- object to our processing of your personal information; and
- not be subject to automated decisions about you and to request human intervention.
For more information and to exercise your rights, please contact us using the details below.
Support: If you need any help with our careers services, please contact our recruitment team at firstname.lastname@example.org.
Privacy: If you have any questions, concerns or complaints relating to the handling of your personal information and your privacy, please email email@example.com.
Lodging a complaint
If we cannot resolve your complaint, you have the right to complain to the UK’s Information Commissioner’s Office at https://ico.org.uk or your local Data Protection authority.
Changes to this Privacy Notice
We will keep this Privacy Notice updated and, if you still have a user profile, keep you informed of any material changes to the way we process your personal information. We encourage you to read about the changes so that you keep up to date. The date this Privacy Notice was last updated appears at the top of the page.
Date: August 2019
Detail: First published
Date: January 2022
Detail: Inclusion of version history table
Update of systems used to process personal information
Update cross-border transfer section