1. Introduction
At Butlins Skyline LTD we are committed to complying with applicable data protection, privacy and e commerce laws. We work very hard to keep your information safe and we follow strict security procedures for the storage and use of your personal information.
We know it may seem like a lot of information, but we recognise that it is important for you to understand how we use your personal information and want you to be appropriately informed about your rights and how we use your data as a job applicant and throughout the recruitment process.
We hope that this notice will answer any questions you may have, but if not, please do get in touch via the details provided in section 17.
We may update this notice from time to time. If there is any significant change, we will let you know, but you’re welcome to come back and check it whenever you wish.
For your information this privacy policy was last updated on 18 January 2023
2. Who are Butlins Skyline LTD?
Butlins Skyline LTD owns and operates three large seaside resorts in the UK, also providing caravans for sale at some of our resorts.
For simplicity throughout this notice, ‘we’ and ‘us’ means Butlins Skyline LTD and its business units.
We have a legal duty to protect personal information that we collect under Privacy Legislation such as, the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018 (the “DPA 2018”) and the Privacy and Electronic Communications Regulations 2003, (PECR).
It is important that you understand who is responsible for keeping your data safe. For the purpose of the Data Protection Legislation we are the data controller and are located at 1 Park Lane, Hemel Hempstead, HP2 4YL. If you have any queries relating to this policy, you may contact us on [email protected] or on 01442 203838.
3. Personal information we collect about you
Personal data, or personal information, means any information about you that enables you to be identified. This includes information either on its own or when linked with any other data. It does not include data where your identity has been removed (anonymous data).
To proceed with your job application, we may collect, store, and use the following categories of personal information about you as listed below. This policy applies to all personal data whether it is stored electronically, on paper or on other materials.
There are also “special categories” of more sensitive personal data which may be requested where applicable. These categories will require a higher level of protection.
We have also detailed the lawful basis for our use of this information. We primarily base our processing of your personal data to pursue of legitimate interests, in order for us to perform our contractual obligations as an employer and to enable us to comply with legal obligations (“Legal obligations”).
We have listed purposes and grounds for processing your personal data in the table below. Please note, some of the grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Butlins collects the following information (“Personal Information”) about you from your application (electronically, in writing, or verbally)
Category of personal data: Your Profile: name, title and contact details including address, email and telephone number(s)
Purpose: To communicate with you in relation to our job vacancies and the recruitment process
Lawful basis: Legitimate Interest - Talent management
Category of personal data: CV: details of your education, qualifications, skills, experience and employment history
Purpose: To assess your skills, qualifications and suitability for a role with us
Lawful basis: Legitimate Interest - To assess your suitability for the position applied for.
Category of personal data: Salary/Compensation and Benefits: information about your current level of remuneration, including benefit entitlements
Purpose: To assess your skills, qualifications and suitability for a role with us
Lawful basis: Legitimate Interest - To assess your suitability of the position applied for.
Category of personal data: Interview Notes: questions and answers provided by you at interview stage, and notes produced by interviewers
Purpose: To assess your skills, qualifications and suitability for a role with us
Lawful basis: Legitimate Interest - To assess your suitability of the position applied for
Category of personal data: Disability status
Purpose: To make reasonable adjustments
Lawful basis: Legal obligation + employment law obligation
Category of personal data: Right to Work: documents and information in relation to your right to work in the UK.
Purpose: To verify whether you are eligible to work in the UK.
Lawful basis: Legal obligation + employment law obligation
If your application is successful and Butlins makes you an offer of employment, this offer will be conditional on receipt of further information (from and about you) being satisfactory. Depending on the job and location, and subject to relevant privacy and employment laws, Butlins may request:
Category of personal data: References: information from your previous academic and/or employment history, from references obtained about you from previous employers and/or education providers
Purpose: To assess your skills, qualifications and suitability for a role with us
Lawful basis: Performance of contract
Category of personal data: Evidence of qualifications: evidence of your academic and/or professional qualifications
Purpose: To assess your skills, qualifications and suitability for a role with us
Lawful basis: Performance of contract
Category of personal data: Driving Licence: a copy of your driving licence(s) where applicable.
Purpose: Duty of care obligations and assessment of suitability.
Lawful basis: Performance of contract
Category of personal data: Additional Information: any additional information relevant to the role you are being offered
Purpose:To assess your skills, qualifications and suitability for a role with us
Lawful basis: Performance of contract
Category of personal data: Documents and information in relation to your criminal convictions and offences history (where applicable)
Purpose: Where Butlins seek to hire individuals in certain roles it may be necessary to carry out criminal record checks this is only where we need to ensure that.
Lawful basis: Legal obligation + legitimate interest & employment, social security and social protection In addition to having a lawful basis, where we are processing criminal records data, we require a condition for processing in Schedule 1 of the DPA18.
To meet the condition, we will need to demonstrate that processing is both necessary to perform or exercise our obligations in connection with employment and have an appropriate policy in place
Category of Special Category data: Information about: ethnic origin, sexual orientation, religion or belief.
Purpose: To monitor recruitment statistics and the diversity of our workforce.
Lawful basis: Legal obligation + employment law obligation + We rely on DPA schedule 1 conditions to process special categories of personal data, specifically in Part 2 - Substantial Public interest (Equality of opportunity or treatment).
To meet the condition, we will need to demonstrate that processing is both necessary to perform or exercise our obligations in connection with employment and have an appropriate policy in place.
Category of Special Category data: Information about health
Purpose: To make reasonable adjustments processing personal data concerning health in connection with
Lawful basis: Legal obligation + employment law obligation
Once you have accepted an offer of employment and relevant conditions have been satisfied, we will request further information from you. This processing will be subject to our Employee Privacy notice. Which will be provided to you at onboarding.
4. How do we collect your personal information?
We collect personal information about you also through the application and recruitment process either directly from you, or from third parties e.g recruitment service providers, if they were involved. We sometimes collect additional information from other third parties including former employers, authorities or other information providers where applicable.We may collect this in writing, electronically or verbally.
Subject to the applicable laws, information may be obtained through background checks, security clearances and other similar information sources deemed necessary due to the nature and security requirements related to the open position in question. We will seek information from these third parties only once a job offer to you has been made and would inform you before doing so.
For further information on how we collect information about you please contact us on the details provided in section 17.
6. Change of purpose
We will only use your personal information 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 we need to use your personal information for an unrelated purpose or purpose for which you would not reasonably expect during the course of the employment relationship, we will notify you and explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. If you fail to provide personal information
Butlins is under a statutory obligation to collect information from you regarding your nationality and immigration status and information from related documents, for the purpose of verifying your right to work in the United Kingdom.
Aside from the above, you are under no statutory or contractual obligation to provide data to Butlins during the recruitment process. However, if you do not provide the information, Butlins may not be able to process your application properly or at all.
8. Automated decision making
In some cases you may be subject to automated decision-making during the recruitment process. E.g where you do not have the right to work in the UK. In all other situations there will always be human intervention on any decisions based on automated processing, including automated analytics, testing, profiling.
However, if this position changes, or there is a need and lawful basis to do so, we will notify you in writing.
9. Who do we share your personal data with?
We may share your personal information with various departments within Butlins Skyline LTD for the purposes of the recruitment process. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area for which you may be considered and IT staff if access to the data is necessary for the performance of their roles.
Butlins will not otherwise share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. It will then share your data with former employers to obtain references for you, background check providers to obtain necessary background checks in relation to your employment history, where relevant, driver records at the DVLA, and, where permitted by law, the Disclosure and Barring Service to obtain necessary criminal records checks or:
• if it, or substantially all of its assets are acquired by a third party, in which case personal data held by Butlins about applicants and employees will be one of the transferred assets; and/or
• if Butlins is under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply its agreements; or to protect the rights, property, or safety of it, its applicants, employees, customers and providers.
In all cases here’s the policy we apply when sharing data to keep your data safe and protect your privacy:
• We provide only the information they need to perform their specific services. • They may only use your data for the purposes specified in the Data Sharing Agreement with them
• We work closely with them to ensure that your privacy is always respected and protected. • If we stop using their services, any of your data held by them will either be deleted, returned or rendered anonymous.
10. Storage and transfer of your personal data
Data will be stored securely in a range of different places, including on Butlins online application platform, your application record, in HR management systems and on other IT systems (including email). We may also store some personal data in paper filing systems.
Personal information that we collect from you may be transferred to, and stored in destinations outside the European Economic Area, (the "EEA”). Where this is the case we will only use service providers where the processing will take place in a country whose data protection rules are deemed adequate by the European Commission (“EC”) To protect your personal information, we ensure that appropriate safeguards are in place which provide adequate levels of protection of your personal data and the mechanisms in place have been recognised or approved as required by applicable data protection laws, by the relevant authorities. If you have questions about the transfer of your personal data please contact our data protection officer.
11. How do we protect your personal data?
In all cases we treat your information with the utmost care and take all appropriate steps to protect it. We have put in place appropriate physical, technical and administrative security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
When we have provided (or you have chosen) a password allowing access to our online application platform, you are responsible for safeguarding it and keeping it confidential, and you undertake not to allow it to be used by third parties.
Unfortunately, the transmission of information through the internet is not completely secure. Although we will take all reasonable commercial measures to protect your personal data, we cannot guarantee the security of personal data you disclose online. To the extent permitted by law, we will not be responsible for any breach of security if it occurs notwithstanding such measures.
12. How Long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. This period will be determined based on any business and/or legal requirements.
Details of retention periods for different aspects of your personal information are available in our retention policy which is available on request. 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.
At the end of the relevant retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
13. Cookies and other tracking technology
Our website uses “cookies” and other tracking technologies which are placed and stored on your device or in browser memories, if you agree, when you visit our website. These are used for various purposes, including distinguishing you from other website visitors. For more information on our use of cookies, please see our cookies policy.
14. Your rights in connection with personal information
You have certain rights in respect of the personal information that we hold about you.
We will process all personal data in line with your rights, in each case to the extent required by and in accordance with applicable law only (including in accordance with any applicable time limits and any requirements regarding fees and charges). We will always respect your personal information rights. For more information on your rights, please see: https://ico.org.uk/your-data-matters/
To exercise any of these rights, please contact us at [email protected]
15. Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes during your working relationship with us.
16. Changes to this privacy notice
We reserve the right to modify this privacy policy from time to time.
Any changes we make in the future will be posted at https://jobs.butlins.com/ You should check back frequently to see any updates or changes to our privacy policy.
17. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
Questions, concerns, comments, requests or complaints regarding this privacy policy, our website and/or our use of your personal information should be addressed to the DPO at [email protected], by post to 1 Park Lane, Hemel Hempstead, HP2 4YL or you can phone us on 01442 203883.
If you have any complaints regarding this privacy policy, you may also contact the UK Information Commissioner at telephone number 0303 123 1113 or https://ico.org.uk/make-a-complaint