Global candidate privacy notice

1. WHAT IS THE PURPOSE OF THIS DOCUMENT? 

Inchcape is an independent, multi-brand automotive distributor with operations that span countries on five continents. This Privacy Notice informs you of how Inchcape and its subsidiaries and/or affiliates (“Inchcape”, “We” or the “Company”) will collect and manage Candidate Personal Information. It also describes the Company’s expectations for those who collect and manage Candidates’ Personal Information.  

We are dedicated to ensuring that all personal data that we process is done so in a fair, lawful and transparent manner. We take the security of your data very seriously and adhere to all relevant data protection legislation including the Data Protection Act 2018, the UK General Data Protection Regulation and The Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”).   

In addition, many countries have specific legal requirements governing the use of Personal Information, including Candidate Personal Information. The Company will comply with all laws and regulations, including local data protection and co-determination laws, and will implement additional procedures, standards, and policies wherever needed to meet these requirements. Accordingly, the actual Candidate Personal Information collected and/or accessed by Inchcape may differ from jurisdiction to jurisdiction to comply with local laws. 

Inchcape is a “data controller”. This means that 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. 

This Privacy Notice is relevant to you because you are applying for work with us (whether as an employee, worker or contractor). It is important that you read and retain this Privacy Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, how long it will usually be retained for and what your rights are under the data protection legislation.  

The Company makes reasonable efforts to ensure that Candidate Personal Information is reliable for its intended use. Candidates are equally responsible for updating and checking the accuracy of the information they or others provide to Inchcape on their behalf. 

2. DATA PROTECTION PRINCIPLES 

We will comply with applicable data protection laws.  We will ensure that any personal information we hold about you is: 

• Used lawfully, fairly and in a transparent way. 
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. 
• Relevant to the purposes we have told you about and limited only to those purposes. 
• Accurate and kept up to date. 
• Kept only as long as necessary for the purposes we have told you about. 
• Kept securely. 

3. WHAT KIND OF INFORMATION DO WE HOLD ABOUT YOU? 

We collect and manage the minimum amount of Candidate Personal Information in compliance with applicable legal requirements to promote Inchcape as a potential employer and increase the number of Candidates; to assess the Candidate’s employment application; to facilitate the Candidate’s onboarding as an employee if an employment offer is extended and/or accepted; and to keep the Candidate informed of additional roles of relevance to their employment interests and goals.  

We will always minimise the types and amount of Candidate Personal Information the Company may collect from or about you. However, the collection of information and access to such information will vary depending on country-specific legal and/or business requirements. We will notify you at the point of collection whether the Candidate Personal Information that we request of you is required or is voluntary to proceed with your recruitment process. 

In connection with your application we will collect, store, and use the following categories of personal information about you: 

• The information you have provided to us in your curriculum vitae and covering letter.  
• The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, educational and vocational experience and qualifications. 
• Any information you provide to us during the application process or at an interview. 
• Proficiency tests results and psychometric reports, as required. 
• If legally allowed in a particular county, we may also collect, store and use the following types of more sensitive personal information: Information about your race or ethnicity, religious beliefs, sexual orientation, disability status. 
• If legally allowed in a particular county, we may also collect, store, and use information about criminal convictions and offences. 
• Any information you provide to us via the Equal Opportunities Form as part of the application process or otherwise (if applicable). 

4. HOW IS YOUR PERSONAL INFORMATION COLLECTED? 

We collect personal information about candidates through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.  

5. UNDER WHAT LEGAL AND/OR BUSINESS BASIS DO WE PROCESS CANDIDATE PERSONAL INFORMATION? 

In most countries, the primary legal and/or business basis for collecting and using Candidate Personal Information is your consent. In certain countries, the legal and/or business basis may also be pre-employment contract data processing requirements, our legitimate business interests, and/or to comply with legal obligations. For further information on your right to withdraw consent, and the consequences thereof, see details below. 

6. HOW WILL INCHCAPE USE INFORMATION ABOUT YOU? 

We will use the personal information we collect about you to: 

• Assess your skills, qualifications, and suitability for the role (or roles, as the case may be). 
• Carry out background, medical and reference checks, where applicable. 
• Communicate with you about the recruitment process. 
• Keep records related to our hiring processes. 
• Comply with legal or regulatory requirements. 
• Deciding to shortlist, interview, employ or appoint you. 
• If you decide to complete the separate, voluntary Equal Opportunities Form for us to meet our company aspirations in respect of equality and diversity (it is not required that you complete this as part of your application, this information is solely collected to create statistics and is not used as part of the recruitment decision making process). 
• Depending on your profile visibility options, highlighted below, you may be added to a talent pool by the HR recruitment team at Inchcape if your vocational and qualification skill set match an opportunity at Inchcape. Inchcape’s HR recruitment team may use this to contact you about any opportunities which your skillset matches for and invite you to apply for roles. 
• Send you a feedback survey on your experience. (Your response to the survey is voluntary, and Inchcape alone can view and use the survey results. The survey doesn’t require you to enter any sensitive confidential or proprietary information of anybody.) 
• Use your feedback experience to investigate and improve our recruitment systems. 

Having received your curriculum vitae/covering letter/application and the results from any background checks and/or tests, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you are shortlisted, we will decide whether to invite you for an interview. If we decide to invite you for an interview, we will use the information provided and any additional information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we may then take up references and/ or carry out a criminal record and/ or carry out any other checks. Following the successful completion of this process, we will confirm your employment or appointment in writing. 

It is in our legitimate interests to collect and process your personal information for the purposes set out above to decide whether to shortlist, interview, assess or employ or appoint you for the role (or roles) that you have applied for. Inchcape also relies on the legitimate interest legal basis in the processing of feedback survey information to further improve the experience for all candidates.   

We also need to process your personal information to decide whether to enter a contract with you (such as a contract of employment or a contract for services). 

If you fail to provide personal information 

If you fail to provide information when requested, which is necessary for us to consider your application, (such as evidence of qualifications or work history) this may delay or obstruct the processing of your application. 

7. HOW DOES INCHCAPE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION? 

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.  

If legally allowed in particular country, we may process special categories of personal information in the following circumstances: 

1. In limited circumstances, with your explicit written consent. 
2. Where we need to carry out our legal obligations or exercise rights in connection with employment.  
3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme. 

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.   

8. DOES INCHCAPE COLLECT INFORMATION ABOUT CRIMINAL CONVICTIONS? 

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with legal requirements and this Privacy Notice. 

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.   

9. YOUR CHOICES: 

When you create a recruitment profile you will be given some choices as to how Inchcape can store, share your data, and communicate with you. You can make your profile visible to Inchcape’s HR recruitment team in the following ways: 

• Any Company Recruiter Worldwide: If you select this option, any recruiter will be able to search your profile and possibly contact you if you have the skills to potentially fulfil a role. The recruitment team at Inchcape work across different regions to identify talent, the recruitment system only allows candidates to be searchable and contacted about future opportunities if this option is selected. By selecting this option, you may be contacted by any HR recruiter regarding roles. This is the most unrestricted visibility option. 

You also have a choice as to how freely Inchcape interacts with you. You have two notification choices when you create a profile. You can change these choices at any time by amending the selection in your profile by visiting the ‘’Search Options & Privacy” section of your profile. 

• Receive New Job Notifications: This is a way for you to indicate to Inchcape that you are happy for Inchcape’s recruitment system to send regular automatic email notifications to you. You still retain control. Although you have indicated this option, you create the Job Alert in the system which will contact you at the regularity you set (i.e., every 7 days), and under the search criteria you are interested in. You can remove these Job Alerts at any time by visiting your recruitment profile and deleting the Job Alert(s).  
• Hear More About Career Opportunities: Select this option if you want Inchcape’s HR recruitment team to pro-actively contact you in respect of roles where Inchcape has identified you as a possible candidate based on your vocational and qualification skill set. This will be ad hoc depending on when opportunities arise. If selecting this option, please ensure you have chosen the right level of visibility (as above) otherwise the HR recruiter will not be able to search for you or contact you about future opportunities at Inchcape. 

You can change these choices at any time by amending the selection in your profile by visiting the ‘’Search Options & Privacy” section of your profile. 

10. DOES INCHCAPE PERFORM AUTOMATED DECISION-MAKING?   

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. 

11. DOES INCHCAPE PERFORM DATA SHARING? 

Why might Inchcape share my personal information with third parties? 

We share your personal information within the Inchcape Group (which could include the relevant group company within which the role is based), depending on the choices you have made on your profile (see above) and with the following third parties for the purposes of processing your application, for example, a medical background check provider, Customer thermometer (for feedback survey). All our third-party service providers and other entities in the Inchcape Group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions. 

12. HOW DOES INCHCAPE MANAGE DATA SECURITY? 

We have put in place appropriate security measures to protect your personal information. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. 

13. HOW DOES INCHCAPE MANAGE DATA RETENTION?  

For how long will Inchcape use my information? 

Retention of the personal information provided will depend on your progress through the recruitment process and employment or appointment (if successful). Should you be successful, your personal information will be retained until your relationship with Inchcape comes to an end.  

If, however, you are unsuccessful, your personal information and application profile will be retained for a period of time dependent on local applicable laws, and in any event for no longer than is necessary (this could be a period between a couple of months to a year, or until such time as you choose to delete your personal information or request your personal information is deleted, subject to applicable laws) – we retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. 

14. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION 

Your rights in connection with personal information 

Under certain circumstances, by law you have the right to: 

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. 
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. 
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).  
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.  
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.  
• Request the transfer of your personal information to another party. 

If you want to review, verify, correct, or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact your contact at Inchcape or contact us using the details below. 

15. RIGHT TO WITHDRAW CONSENT 

When you applied for this role, if you provided consent to us processing your personal information for a particular purpose during the recruitment exercise, you have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact your contact at Inchcape or contact us using the details below. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal information securely. 

16. CONTACT INFORMATION 

If you have questions about your Candidate Personal Information, want to exercise any of your rights under applicable data protection laws or have concerns about a potential data breach, you can contact us by: 

Email: contact@inchcape.com  

Post: Group Legal Counsel, Inchcape plc, 22a St James’s Square, London, SW1Y 5LP 

17. FUTURE MODIFICATIONS 

Inchcape reserves the right to modify this Privacy Notice as needed, for example, to comply with changes in laws, regulations, Company practices and procedures, or to respond to new threats or new requirements imposed by data protection authorities. Where such changes materially affect our processing of your Candidate Personal Information, we will accordingly notify you.