Last Updated: August, 2020
Privacy Statement for Job Applicants
Minor International respects your privacy and is committed to protecting your personal data. As part of recruitment process, we will collect information about you and this privacy statement will inform you as to how we look after your personal data. It will tell you about your privacy rights and how the law protects you.
It is important that you read this statement together with any other privacy statement or fair processing statement we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy statement supplements other notices and privacy policies and is not intended to override them.
By entering the recruitment process you are agreeing to provide current, accurate and truthful information.
1. Data Controller
This privacy statement is issued on behalf of the Minor International PLC and our affiliated entity that performs the recruitment process (“Minor Group”, "we" or "us"). 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.
2. How is your personal data collected?
This privacy statement also aims to give you information on how we collect and process your personal data. We may collect personal data directly from you, including from applications and documents that you submit to us and information you provide to interviewers during the recruitment process. We may also collect personal data from our external career’s websites, third party recruitment agencies, service providers, any police or background checks, LinkedIn, third parties you have authorised to deal with us on your behalf and from the referees you have given us permission to contact.
3. Purposes for which we will use your personal data
We need to process data to take steps at your request prior to entering into a contract with you. In some cases, we may need to process data to ensure that we are complying with its legal obligations.
Minor Group has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess a candidate’s suitability for employment and decide to whom to offer a job.
We may process special categories of data, such as information about ethnic origin to monitor recruitment statistics and equal opportunity monitoring and reporting. We may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. We process such information to carry out its obligations and exercise specific rights in relation to employment.
Your information may be shared with other entities with the Minor Group for the purposes of the recruitment exercise. We may share your personal data with third parties for the purposes of recruitment.
All applicants have the option to consent to Minor Group keeping the data and have the option to withdraw consent at any time.
4. Legal basis on which we collect your data
These data processing may be for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below:
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:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else's interests).
2. Where it is needed in the public interest [or for official purposes].
5. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (“Aggregate Data”).
We may collect, use, store and transfer different kinds of personal data about you which we have arranged according to the different purposes as follows:
Identity Data: full name, username or similar identifier, nationality, marital status, dependents, title, date of birth and gender, ID, picture, signature.
Contact Data: home address, email address and telephone numbers.
Employment information: previous employment information, job title, education, salary expectations.
Recruitment data: copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process;
Technical Data: IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use.
Sensitive Personal Information
In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment. The situations in which we will process your particularly sensitive personal information are listed below:
- 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 including statutory maternity pay, statutory sick pay, pensions and health insurance.
- We will use information about your religious, philosophical or moral beliefs, to provide appropriate adjustments to your work.
- We will use biometric data of fingerprint scans and facial recognition to control access to facilities.
- We will use information about criminal convictions and offences to determine your suitability for roles you apply for.
- We will use information about your race or national or ethnic origin to ensure meaningful equal opportunity monitoring and reporting.
6. Disclosures of Personal Data
We share Personal Data with the companies belonging to Minor Group and owners of our outlets and hotels for the purpose of finding a suitable position and administration of the recruitment process and third parties to conduct background checks.
We require all third parties to respect the security of your personal data and to process it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may contact referees, professional or educational institutions whose details are provided by you, as part of our standard recruitment process.
Applicants with criminal records are not automatically barred from applying for any position. Only some positions will require a criminal history check due to the inherent requirements of the role and associated legislative requirements in which case all shortlisted applicants for the relevant position will be asked to consent to a criminal record check. Each application will be considered on its merits.
7. International transfers
As a global company, we may transfer your Personal Data across multiple jurisdictions, insofar as it is necessary for the purposes your Personal Data may be transferred to the following locations:
- Countries where our corporate offices are located;
- Countries in which we manage and operate food & beverage outlets, retail outlets, hotels, residences, manufacturing facilities and/or sales offices etc.; and
- Countries where our third-party service providers, advisors, and consultants are located, which changes from time to time.
- Where Personal Data is transferred to a country with a lower level of data protection as compared to the country in which the information was collected, we take all reasonable steps to ensure that your information and privacy are protected in line with the applicable legal obligations. Whenever we transfer your personal data, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts provides suitable protection measures which enable the enforcement of the data subject’s rights, including effective legal remedial measures according to the rules and methods as prescribed and announced by the Committee.
Minor Group could use the consent of the data subjects as well as any other regulation that the applicable law provides.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. However, it also has regard to legal risk and may keep records for up to seven years (and in some instances longer) after your employment or work with us. This may change depending on the requirements of the applicable country.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your onboarding process and retained during your employment. The personal data will be held as per our Data Retention Policy.
If your application is unsuccessful, we will hold your information on our system for 3 years after the end of the relevant recruitment process, after which it will be securely destroyed. You may contact us via email email@example.com to exercise your data subject rights.
9. Processing of third parties’ data
In the event that you provide data from third parties, you declare to have their consent to do so and you agree to transfer the information contained in this clause, as well as inform Minor Group of any change or update relating to them. The employee guarantees that those affected are over 18 years old or, otherwise, that they have the informed consent of their parents or guardians to communicate the information.
10. Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Request to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please submit your request through written communication to your relevant Human Resources department or the Data Protection Team using the details below:
Email: firstname.lastname@example.org; or
Post: 12th Floor, 88 The PARQ Building, Ratchadaphisek Road, Khlong Toei, Bangkok 10110, Thailand
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances and we will indicate the reason for refusal.
11. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
This helps us make our website relevant to your interests and needs. We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so we can recognize you if you visit our website again.
The type of cookies we use on this site include:
Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Analytics Cookies: We use these cookies to analyse and identify the behaviour of our web visitors. We will track the IP address on the device you are using to identify you when visiting our website. When possible we combine your online web behaviour data with the personal data that you have previously supplied to us. This data will be used to analyse behaviour on our website and to personalise your experience.
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Engagement Cookies: These cookies are used to provide additional functionality to the site and may affect your experience if they are turned off. They are used to allow enhancement widgets for live chat to provide customer support or alert widgets drawing your attention to updates and exclusive offers. These cookies may track your customer journey to personalise the support and messaging given.
If you wish to block the cookies please visit:
- Google AdWords - https://adssettings.google.com/authenticated
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- Twitter Advertising - You may disable tailored advertisements via your Twitter settings by visiting the “Promoted content” and “Personalization” sections.
- Google Analytics - You may disable any of these cookies via your browser settings or by downloading a browser add-in: https://tools.google.com/dlpage/gaoptout.
You may disable any of these cookies via your browser settings.
13. Changes to this Privacy Statement
We keep our Privacy Statement under regular review and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.