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UK/EU Lazyrun Applicant Privacy Notice
Effective Date:February 8, 2024
lazyrun APPLICANT PRIVACY NOTICE
1. INTRODUCTION
This Applicant Privacy Notice describes the personal information that companies in the lazyrunGroup (collectively, “lazyrun
,” “we”, “us”, and “our”) collect, use, disclose, transfer, and store (collectively, “process”) in connection with our recruitment activities.
Your data controller will be GoBrands UK Holdings Ltd. or the company specified within the description of the role to which you apply. Your data controller decides why and how your personal information is processed. Please see the paragraph at the end of this notice for our contact and company information.
This notice explains:
why and how we may use the personal information that we have obtained as a result of you applying for a role with us (whether as an employee, worker, independent contract delivery partner or in any other capacity), and our recruitment activities in the UK and EU;
with whom we share your personal information; and
the rights you have in connection with the personal information we use.
This notice applies to:
information we process in connection with our recruitment activities, including if you apply to work with lazyrun (as an independent contract delivery partner, or in any other capacity) in the UK or the EEA; and
personal information we process of any third parties in connection with your application for a role with us.
This notice may change from time to time so please check this notice occasionally to ensure that you are happy with any changes. For more information on changes to our notice, please see paragraph 11 (Changes to this notice). If we make material changes, we will provide you with additional notice, such as by sending you a notification.
2 APPLICABILITY OF OTHER NOTICES
This notice does not cover our processing of personal information collected from you:
as a lazyrun customer or visitor to our sites or mobile applications. To learn more about lazyrun privacy practices in those cases, please see our UK lazyrun Privacy Notice; or
as a lazyrun employee (once an offer of employment has been accepted by you). To learn more about lazyrun privacy practices in those cases, please refer to our UK/EU lazyrun Applicant Privacy Notice which will be provided to you if an employment offer has been made to you and accepted by you.
3. PERSONAL INFORMATION WE COLLECT ABOUT YOU
Most of the personal information we collect is obtained directly from you when you use our careers website, apply for a role with us and during the recruitment process. We also collect personal information from third parties where required as part of our recruitment activities.
We also collect personal information automatically, such as when we monitor the use of our premises via CCTV. We may also collect certain information through cookies and similar technologies, such as analytics information when you visit our careers site – please see our lazyrun UK Privacy Notice for further information.
Personal information you give to us or we generate about you:
Identifiers, such as your name, title, postal address, signature, unique personal identifier, online identifier, internet protocol address, email address, social security number, driver’s license number, passport number, date of birth, citizenship and other similar identifiers;
Formal identification documents, such as your passport, national insurance number, social security number, visa documentation or driving licence information;
Work eligibility information, such as your nationality, immigration status, formal identification documents, utility bills and other documents required to confirm your right to work;
Characteristics of protected classifications under applicable law, such as age, gender, marital status, race, ethnicity, sexual orientation, veteran status, and disability status;
Professional and employment-related information, such as your applications, resumes, cover letters, employment history, information provided to us during an interview, shared with us by references, or included in background checks (where applicable), and our assessment of recruitment information; performance reviews and disciplinary reports; job title, picture, and employee number; current salary, and other work-related documentation including records, forms, logs and agreements;
Education information, such as the name of the education establishment you attended, your degree information and graduation dates;
Information you provide to us through the interview or recruitment process, such as your opinions on certain matters and career aspirations; and
Health and health-related information, including any medical condition, health and sickness records.
Information we collect about you from other sources:
We may obtain the following personal information about you from the following sources, which we use in the ways described in the section below:
Third Party Name | Categories of Data Collected |
Other lazyrun group companies | All types of personal information described above in this notice |
Recruitment agencies | Identifiers, professional and employment-related information, Education information |
Background checking providers | Information about criminal convictions and offences, including Disclosure and Barring Service (DBS) checks (for individuals located in the UK) and equivalent checks for individuals located in the EEA, as well as other criminal history checks |
Credit reference agencies | Information relating to any bankruptcy event |
Local driver and vehicle licensing agencies | Driving licence record details, including details concerning any penalty points and other driving offences |
Publicly accessible sources (e.g. social media or other websites). | Personal information you may publish or which is published about you on publicly accessible social media or websites (such as via LinkedIn or your own personal website), or that you disclose to us via such medium (e.g. by applying for roles via LinkedIn). |
Your previous employer | References, including performance and employment history |
Your previous educational institutions | Prior education and qualifications |
Special category personal information
In some cases, we may collect personal information that is sensitive in nature or requires a higher level of protection under certain laws. Please note that, where permitted by law, we may collect, store, and use information such as biometric information and information that may reveal details about your race, ethnicity, sexual orientation, trade union membership, disability status, and health and medical conditions.
We collect this information for specific purposes, such as to accommodate a disability or illness, comply with legal obligations such as anti-discrimination or diversity regulations (where applicable), protect the health and safety of applicants, and facilitate internal programs relating to diversity, equity, inclusion, and anti-discrimination. We will use sensitive personal information for the purposes set out in this notice, or as otherwise described to you at the time such information is collected, and in accordance with applicable law.
CCTV monitoring
When you visit our premises as part of the recruitment process, for example for an interview, we reserve the right to monitor the use of our premises.
In the event such monitoring occurs, it may result in the collection of personal information about you. Some lazyrun facilities, such as our corporate offices, distribution centers, and our stores, are equipped with surveillance equipment, such as cameras and CCTV. This equipment may capture your image or information about your movements, which lazyrun uses to protect the safety of our staff, visitors, and property, to monitor and troubleshoot issues with equipment or technology in compliance with our legal obligations and where necessary to achieve our legitimate interest set out in paragraph 4 (How and why we use your personal information).
Information about others
If you provide us with personal information of a reference or any other individual as part of your application, employment, or engagement with us, it is your responsibility to obtain appropriate permission from that individual prior to providing such information to us.
4. HOW AND WHY WE USE YOUR PERSONAL INFORMATION
We use your personal information to evaluate a potential engagement with you, and for other business purposes, including managing our business and complying with specific legal obligations. The lawful basis on which we rely to process your personal information for each purpose is as follows:
Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
Processing which is necessary as part of the recruitment process to identify individuals who would be suitable employees for an available role
to manage our hiring and recruiting activities, such as to assess your skills, qualifications, and suitability for a particular role or opportunity, communicate with you about the recruitment and hiring process, respond to your requests, inquiries, and comments, verify your information, if we offer you a position or other opportunity with us.
Processing which is necessary for us to identify how our application process can be improved including through the analysis of applicant demographics:
to ensure our application forms and interview process are not restricting the type of applicants we attract and to find ways to maximise the number of potentially suitable applications to enable us to recruit from a diverse and wide talent pool.
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively:
for network and information security data, to take steps to protect your information against loss, theft or unauthorised access;
to prevent and detect fraud; and
to enforce or defend our legal rights or any claims.
Processing necessary to maintain the security and protection of our premises and property on our premises, and for your health and safety while on our premises:
to monitor you via CCTV to prevent and detect damage to our premises and health and safety incidents.
Where we have obtained your CONSENT
We process your personal information where we have obtained your consent, including for the purposes of holding your details for use in future applications. See further paragraph 7 (The period for which we keep your information) below.
You can withdraw your consent at any time by contacting us using the details at the end of this notice. The use of your information that we make before you withdraw your consent will remain lawful.
Where necessary to comply with our LEGAL OBLIGATIONS
to protect the health and safety of lazyrun applicants, such as to implement internal policies, identify, investigate, and respond to security incidents, or other activity that is unlawful or puts lazyrun applicants in danger;
to promote diversity and inclusion within lazyrun by complying with our legal obligations and internal policies relating to diversity, equity, inclusion, and anti-discrimination;
as necessary and appropriate to provide reasonable accommodation as part of the recruitment process or where you are attending an interview with us;
to check your eligibility and right to work as required by applicable immigration laws, such as passport and visa documentation;
to verify your identity as required by applicable laws, including identification documentation relating to you, such as a passport or driving licence, (including your date of birth);
to check your driving eligibility, to validate driving licence information where required for the role applied for;
to ensure our Personnel are given equal opportunities and to better identify hidden barriers, relating to diversity, equity, inclusion, and anti-discrimination;
to conduct background checks, where we have a legal right or reason to do so (for further information see ‘How we use information about Criminal Convictions’ below);
to comply with law enforcement and court orders, such as cooperating with law enforcement investigations, comply with applicable laws, regulations, legal processes, or governmental requests, comply with court orders or other notices where failure to do so would result in us breaking the law;
to detect fraud, such as implementing internal policies and monitoring systems to detect, investigate, and respond to suspected fraud;
to comply with a request from you in connection with the exercise of your rights, for example where you have asked us not to contact you for marketing purposes (e.g. information relating to new job roles), we will keep a record of this on our suppression lists to be able to comply with your request);
to anonymise or delete your personal information when it is no longer required, for the purposes described in this notice; and
to handle and resolve any complaints we receive relating to our processing of your personal information as described in this notice.
Where necessary for us to carry out PRE-CONTRACT STEPS you have requested or for the performance of your CONTRACT
We will use your personal information where this is necessary for us to perform a contract with you or to carry out any pre-contract steps you’ve asked us to so that you can enter into that contract, for the following purposes:
to conduct criminal background checks and other checks relating to your suitability for the role, where we are not legally required to do so (for further information see ‘How we use information about criminal convictions’ below); and
to ensure our Personnel are given equal opportunities and to better identify hidden barriers, relating to diversity, equity, inclusion, and anti-discrimination, where we are not legally required to do so.
How we use special category personal information
We may also collect, store and use your special category personal data for a range of reasons, relying on a variety of different grounds for lawful processing under applicable data protection laws, as follows:
for occupational health reasons or where we are assessing your working capability, subject to appropriate confidential safeguards. This may include information about your physical or mental health or disability status to consider whether any adjustments are required during the recruitment process, and for carrying out any medical assessment required for the role, pension and any insurance benefits which may be offered to you as part of the role;
for statistical purposes in the public interest, such as collecting information about your race or ethnic origin, religion or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. Any such information shall only be used in an anonymised form for statistical purposes and will not be used in relation to your application for a role with us;
to enable lazyrun to perform its legal obligations in respect of employment, social security, social protection law, or as needed in the public interest. In the UK, this may include the processing of health information to comply with obligations under the Equality Act 2010; or
to establish, defend or exercise legal claims in an employment tribunal or any other court of law.
How we use information about criminal convictions
For certain roles, where required under applicable local law, we have a legal right / reason, to undertake criminal background checks. Where we do so, we only do so in accordance with our lazyrun UK/EU Applicant Privacy Notice, the principles set out in data protection laws, and the prevailing legislation in the area of criminal backgrounds checks as updated from time to time. For details on how long we retain criminal convictions information and how it is disposed of, please refer to paragraph 7 (The period we keep your personal information) below.
5. DISCLOSURE OF YOUR PERSONAL INFORMATION BY US
We may share your personal data and special category personal data internally. In particular, it may be shared with: HR employees involved in the recruitment process, employee relations and/or administration of your employment; line managers; consultants; advisers; and/or other appropriate persons who may be involved in the recruitment process for the role(s) you are applying for.
We may disclose your information to our third party service providers, agents and subcontractors (Suppliers) for the purposes set out above. Our Suppliers can be categorised as follows:
Recipient / relationship to us | Industry sector (& sub-sector) |
Expense Management | IT Services (SaaS Provider) |
Diversity Programs | IT Services (SaaS Provider) |
Professional Advisors | Professional Services (Legal, accounting, auditing, insurers and banking) |
Communications Platform | Telecommunications (IT networking) |
IT Service Providers | Telecommunications (IT networking) |
Background / Credit Check Providers | Background / credit check providers |
Recruitment Agencies | Recruitment providers |
When we share your personal information with any third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.
We may disclose your personal information to other third parties as follows:
other lazyrun group companies;
any third party who is restructuring, selling or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organisation or similar event; or
where we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, tribunals, regulators, the government or related agencies.
6. WHERE WE STORE YOUR PERSONAL INFORMATION
lazyrun is based in the United States and we process and store personal information on servers located in the United States. We also use service providers to process personal information, which may be located in (or have servers in) the United States or other countries.
We provide adequate protection for the transfer of personal information in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions together with international frameworks, relying on adequacy regulations provided by the relevant UK Secretary of State, executing model clauses (including relevant EU Standard Contractual Clauses or the UK International Data Transfer Agreement/Addendum, as applicable), or complying with another approved data transfer mechanism. Where relevant, you may request a copy of these Standard Contractual Clauses by contacting us at [email protected].
In this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this notice.
7. THE PERIOD FOR WHICH WE KEEP YOUR PERSONAL INFORMATION
When applying for a job with us, we compile and keep a file containing information about you which relates to your application for a job with us. Your personal information will be kept secure and will be used for the purposes of your job application. We will hold your personal information for no longer than a reasonable period of time from the date of application.
Unless one of the exceptions below applies, your personal information will either be deleted completely or anonymised. If we anonymise your personal information (so that it can no longer be associated with you), it falls outside of the definition of personal information under applicable data protection laws, and we may use such information without further notice to you.
The only exceptions to the period mentioned above are where:
the law requires us to hold your personal information for a longer period, or delete it sooner;
where you have raised a legal claim, complaint or concern about the recruitment process us, in which case we will retain your information for a reasonable period of time following the date of that legal claim, complaint or query, whichever is the later, in order for us to manage, deal with and/or defend any such legal claim, complaint or query;
you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
you are employed by us following your application (see further below); or
we have stated a different period in a supplementary privacy notice.
If you are offered and you accept a job with us, your personal information will be transferred to a personnel file. The period for which we keep your personal information varies depending on the role(s) which you have held during your employment with us, and your personal information will be permanently and securely deleted at the end of this period. You will be provided with a separate privacy notice which provides details of our use and handling of your personal information if you accept our offer of employment.
8. SECURITY
We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage.
Where we have provided (or you have chosen) a password allowing you access our systems, mobile applications and digital services, you are responsible for safeguarding it and keeping it confidential and you promise not to allow it to be used by third parties.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information during its transmission to us online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we are at fault.
9. AUTOMATED DECISION MAKING
We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this notice and inform you if this position changes.
10. YOUR RIGHTS
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 1 calendar month from either:
the date that we have confirmed your identity; or
where we do not need to do this because we already have this information, from the date we received your request.
You have the following rights, some of which may only apply in certain circumstances:
Your Rights | Further Information |
To have your information corrected if it is inaccurate and to have incomplete personal information completed | If you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us using any of the details described at the end of this notice. |
To object to processing of your personal information | Where we rely on our legitimate interests as the lawful basis for processing your personal information for particular purposes, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this notice. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data. |
To withdraw your consent to processing your personal information | Where we rely on your consent as the lawful basis for processing your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this notice. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful. |
To restrict processing of your personal information | You may ask us to restrict the processing of your personal information in the following situations: · where you believe it is unlawful for us to do so; or · you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings. |
To have your personal information erased | In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this notice. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. |
To request access to your personal information and how we process it | You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this notice. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information. |
To electronically move, copy or destroy your personal information in a standard, machine-readable form | Where we rely on your consent as the lawful basis for processing your personal information or need to process it in connection with a contract in place directly with you, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file. You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information. |
Rights relating to automated decision making, including profiling | You may also contest a decision made about you based purely on automated processing by contacting us using the information at the bottom of this notice. |
To complain to a data protection regulator | You have the right to complain to your local data protection regulator if you are concerned about the way we have processed your personal information. |
11. CHANGES TO THIS NOTICE
We may review this notice from time to time and any changes will be notified to you by posting an updated version on the https://legal.lazyrun.com/policies and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the https://legal.lazyrun.com/policies, whichever is the earlier.
12. CONTACT AND COMPANY INFORMATION
If you have any questions regarding this notice, please contact us at [email protected].