Privacy Policy

1. Introduction

At Bourne Leisure Limited 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 05 August 2020.

2. Who are Bourne Leisure LTD?

The Bourne Leisure estate includes Bourne Leisure Holdings Ltd & its subsidiaries, which form the Haven, Warner & Butlins brands. The employing entity and data controller within the Bourne estate is Leisure Employment Services Ltd. References in this privacy policy to ‘we’, ‘our’ and ‘us’ and Bourne Leisure means the employing entity, Leisure Employment Services Ltd.

We are located at 1 Park Lane, Hemel Hempstead, HP2 4YL and our Data Protection Officer can be reached Here 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.


Category of personal dataPurposeLawful basisBourne collects the following information (“Information”) about you from your application (electronically, in writing, or verbally)Your Profile: name, title and contact details including address email and telephone number(s)To communicate with you in relation to our job vacancies and the recruitment processLegitimate Interest
Talent management.CV: details of your education, qualifications, skills, experience and employment historyTo assess your skills, qualifications and suitability for a role with usLegitimate Interest
To assess your suitability for the position applied for.Salary/Compensation and Benefits: information about your current level of remuneration, including benefit entitlementsTo assess your skills, qualifications and suitability for a role with usLegitimate Interest
To assess your suitability of the position applied for.Interview Notes: questions and answers provided by you at interview stage, and notes produced by interviewersTo assess your skills, qualifications and suitability for a role with usLegitimate Interest
To assess your suitability of the position applied for.Disability statusTo make reasonable adjustmentsLegal obligation + employment law obligationRight to Work: documents and information in relation to your right to work [in the UK]To verify whether you are eligible to work [in the UK].Legal obligation + employment law obligationIf your application is successful and Bourne 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, Bourne may request:References: information from your previous academic and/or employment history, from references obtained about you from previous employers and/or education providersTo assess your skills, qualifications and suitability for a role with usPerformance of contractEvidence of qualifications: evidence of your academic and/or professional qualificationsTo assess your skills, qualifications and suitability for a role with usPerformance of contractDriving Licence: a copy of your driving licence(s)To assess your skills, qualifications and suitability for a role with usPerformance of contractAdditional Information: any additional information relevant to the role you are being offeredTo assess your skills, qualifications and suitability for a role with usPerformance of contractDocuments and information in relation to your criminal convictions and offences history (Where applicable)Where Bourne seek to hire individuals in specific roles, it will be necessary to comply with the legal obligation to carry out criminal record checks.Legal obligation + employment law obligation

Category of Special Category DataPurposeLawful basisInformation about:
ethnic origin,
sexual orientation, or
religion or belief.
Trade Union Membership.To monitor recruitment statistics and the diversity of our workforceLegal obligation + employment law obligationInformation about healthTo make reasonable adjustmentsInformation about health


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. 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

Bourne 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 Bourne during the recruitment process. However, if you do not provide the information, Bourne 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 into 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 other entities in Bourne Leisure LTD group 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.

Bourne 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 Bourne about applicants and employees will be one of the transferred assets; and/or

• if Bourne 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 Bourne's 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 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:

To exercise any of these rights, please Click here

15. 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. 

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

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 by clicking Here, by post to 1 Park Lane, Hemel Hempstead, HP2 4YL or you can contact us by phone 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

18/05/2021, 23:23:18

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