Virgin Media Limited (“Virgin Media”, “we” or “us”) is committed to protecting and respecting your privacy.
Please take a moment to read it so you know what choices and rights you have about the information we may ask you for or collect about you. This policy may change from time to time so it’s a good idea to come back and read through it every now and then. If there’s a significant change to the policy, we’ll let you know straight away. So, let’s get into it.
What kind of information do you collect, when and how?
How is Your Personal Information Collected?
We typically collect this personal information directly from you through our website, through job advertisements or a recruitment agency. We may sometimes be required to collect additional information from third parties or other publicly available sources. We will take reasonable steps to inform you we collect your personal information from a third party, such as recommend a friend schemes.
What personal information do we collect?
We collect, store, and use your personal information throughout the recruitment process where necessary. We collect various types of data at different stages of the recruitment process:
Initial application details include:
- Contact details
- Address and Postcode
- Qualifications, skills and experience
- Immigration status
- Diversity information such as race/ethnic origin, religion or disabilities
- Any relevant reasonable adjustments required as part of the process; which means for example allowing for different type of disabilities or difficulties
- Remuneration expectations
- Criminal convictions
- Those extra details that you choose to share with us
- Extra details your referees choose to tell us or we receive from others
During the shortlisting and selection process we may also collect, store and use additional information such as:
- Driving licence
- Psychometric or situational judgement test/profile information
- Recorded video through our video interview tool
- Date of birth
- Survey response feedback for the purposes of service quality
- Emergency contacts
If you are successful in being offered a role with Virgin Media we will collect, store and use the following further information necessary to on-board as an employee into our business:
- Banking and Tax information
- Passport or equivalent identity card
- Financial information (where financial background checks are required)
- Remuneration details
If you have stated you have previously worked for Virgin Media, we may refer your application to a relevant People Business Partner to assess your employment history.
Examples of other details collected include:
- Health issues requiring adaptations to working environment
- Reporting and managerial relationships
- Leaves of absence (such as maternity leave, sickness absence)
- Disciplinary / grievance records
- Time and attendance details
- Expenses such as travel and expenses claimed from the bank
- Results of original and ongoing employee screening, where relevant
- Details provided in relation to Conduct policies (such as conflicts of interest, personal account dealing, trade body membership and so on)
- Health & safety incidents, accidents at work and associated records
- Building CCTV images
- Audio recordings of telephone interviews
- Video recordings of interviews
- Notes from face to face interviews
As described in our Cookies Policy we also collect data from you when you visit our website.
Why do we collect this personal information?
To ensure possible employment opportunities are offered to the most suitable candidates, we need to process certain personal information about you. We only process your information where necessary to progress a job vacancy or as required by law or regulatory requirements, so not all the purposes set out below will apply to you all the time.
- Application: during the application process we process a variety of details such as your CV, name, address, employment history, academic and professional qualifications, age, diversity (i.e. gender, ethnicity, disability, sexual orientation), nationality, previous disciplinary matters;
- Assessment: our assessments vary but could include psychometric tests (such as a situational judgement test, ability or personality test), interviews (face to face, telephone or video) and/or technical assessments;
- On-boarding: data collected as part of the application process would be used as part of your employment record collection;
- Quality and Forecasting: we assess demand, the fairness of the recruitment process, ensure compliance with legislation which may require use of more sensitive data such as gender and religion (although this type of data is optional for you to share with us);
- Screening: county court judgements, credit history, penalties for tax evasion, proximity to work, driving licence and skillset.
Our legal basis for processing your data
Where we require your sensitive information as part of the employment process, we will obtain your consent.
We will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
When we need to use your personal data to comply with a common law or statutory obligation.
We ensure a fair selection process exists, not only because this is how we operate but we have legal obligations to do so. For example:
- Employee Demand Forecasting – to monitor fairness of recruitment (anti-discrimination)
- Right To Work review – for example to check you are entitled to work in the UK
When we use your data for a reason that is considered necessary by VM, and a reason that is reasonably to be expected.
We can process your personal data where it is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data. When we use your personal data as part of a recruitment activity, we want to help ensure any role is right for you and tailored accordingly. Plus we want to help find roles that are more suitable for you.
Establishment, exercise or defence of legal claims
Where a legal claim connected with you is likely to arise then we need to to process personal data. We process this personal data, which may include sensitive data in accordance with local laws and requirements for example, we need to take legal advice in relation to legal proceedings or be required by law to preserve or disclose certain information as part of the legal process.
How will we use your information?
We need certain personal information to allow us comply with legal obligations and to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
- Checking you are legally entitled to work in the UK
- Assessing qualifications for a job
- To determine your suitability for a job
- Dealing with legal disputes involving you
- To prevent fraud
- Analysis, quality control and forecasting role requirements
- We can identify, plan and implement reasonable adjustments for your application process
- To successfully and timely on-board and enable payroll and employee benefits
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
As part of the selection process, we perform a number of psychometric and screening checks, where permitted by local law. Your consent will be requested before screening checks are performed. These checks are performed on our behalf by other organisations, such as Korn Ferry, and you will be given the details prior to any checks being made.
Criminal records checks
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.
Credit reference agencies
We will undertake searches about you at credit reference agencies who will supply us with information, including information from the electoral register, in support of our recruitment decision. The agencies will record details of the search but will not make them available for use by lenders to assess your ability to obtain credit. We may use scoring methods to assess this application and to verify your identity. You have the right of access to your personal records held by credit reference agencies. We will supply their names and addresses upon request.
In some cases we operate an automated screening selection process where we have a very high-volume of applications. The tools we use select candidates for certain roles based on driving licence, county court judgement record(CCJs), distance from work, situational judgement tests (SJT) and other qualification based job screening questions. Whilst these are automated decision making systems, should you believe that human intervention or review is required then you can request via our Employee Services “EmployeeServices@virginmedia.co.uk”.
Who do we share your information with?
VM may need to share your personal information internally (both in the country where you may work and in other countries in which we have central operations) and may share it with some external parties or associates of Virgin Media. Some of these third parties and associates may be located outside the EU. Your information will only be shared if it is necessary or required (for example to carry out Pre-employment screening).
Your personal information may be shared internally with the following people:
- Those employees who would have managerial responsibility for you or are acting on their behalf;
- Employees in HR who have responsibility for certain HR processes (for example recruitment, assessment, pre-employment screening);
- Employees in Legal, Conduct, Risk, HR, Regulatory and Fraud with responsibility for investigating issues of non-compliance with laws and regulations, policies and contractual requirements;
- Employees in IT and system owners who manage user access;
- Employees who are part of the interview selection panel;
- Employees in HR who work for our parent company and any associated affiliates;
- Audit and Investigations employees in relation to specific audits/investigations; and
- Security managers for facilities / premises.
Virgin Media may also need to share your information with certain external third parties including:
- Companies who provide candidate interview and assessment services
- Suppliers who undertake background screening on behalf of the bank (credit checking agencies, criminal checking bureaus, etc.)
- Academic institutions (Universities, colleges, etc.) in validating information you’ve provided
- Other third-party suppliers (or potential suppliers), who provide services on our behalf.
To complete our resourcing process, we might share data with other countries.
- Our parent company and associated affiliates operate globally and where required a Global Manager who is based outside of the UK (typically the Netherlands or USA) may review CV’s and interview candidates, for certain roles. Our central HR operates from the Netherlands and USA, so candidates and employee information will be processed in these countries too.
- We use resources in India to help with employee services support, accounting, retentions, care and management of Data Subject Rights.
- We use a company called Avature, based in Argentina, to help with our current applicant tracking system.
Where we share your personal data with another company we make sure that they respect your data protection rights too by putting in place appropriate contract terms.
How long will we keep your information?
We will retain your personal information for as long as necessary to fulfil the purposes we collected it for; such as any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the following:
- 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
- whether we can achieve those purposes through other means and
- the applicable legal requirements.
Typically we will not keep candidate details for longer than 12 months following the submission of an application; unless there are compelling reasons to retain for a longer period. However if you don’t want us to hold your details for future opportunities, then you can contact us and we will respect your rights where we need to and unless otherwise necessary, we will remove them.
How do we protect your information?
Our HR and Recruitment systems are protected to ensure that unauthorised or unlawful processing of personal information, accidental loss or destruction of, or damage to, personal information does not occur. 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.
Where we share information with third parties and other parties located outside of the UK, we only permit them to process your personal data for specified purposes and in accordance with our instructions. We have put in place the appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.
Any information sent to us is protected using robust security methods. The methods we use are industry-standard ensuring data is safeguarded whilst being sent over unprotected communications paths such as the internet. When it reaches us, we store it securely and only provide access to it by those authorised. Although we safeguard your personal information once received, we cannot guarantee the safety of any personal information you transmit to us using online methods.
Our security measures include:
- Encryption of data where appropriate
- Regular penetration testing of systems
- Security controls which protect the entire Virgin Media Information Technology infrastructure from external attack and unauthorised access
- Regular cyber security assessments of all service providers who may handle your personal data
- Regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents
- Internal policies setting out our data security approach
- Training for employees on security and privacy
Your choices and obligations
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.
Your rights regarding to personal information
You have the right (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
- request access to your personal data: this right entitles you to request access to personal data Virgin Media processes about you, as well as to certain information on such processing;
- request rectification of your personal data: this right entitles you to request the rectification or completion of any of your personal data that would be inaccurate or incomplete;
- request deletion of your personal data: this right entitles you to request the deletion of your personal data, including where such personal data would no longer be necessary to achieve the purposes;
- object to the processing of your personal data: this right entitles you to request that Virgin Media no longer processes your personal data;
- request the restriction or objection of the processing of your personal data: this right entitles you to request that Virgin Media only processes your personal data in limited circumstances, including with your consent;
- request a copy or the portability of your personal data: this right entitles you to receive a copy of personal data that you have provided to Virgin Media.
- right in relation to automated decision making and profiling: this right entitles you to request human intervention where you have any concerns about a decision, in case this was made by a machine based on personal information we have.
- right to be informed: this right will make sure you are provided with clear, transparent and easily understandable information about how we use your information and your rights.
If you’re not satisfied with our response to your question or concern, or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) at https://ico.org.uk/global/contact-us/
Write to the address below:
Data Protection Team
Virgin Media Limited
Swansea SA7 9BB
PO Box 333
Send us an email to: EmployeeServices@virginmedia.co.uk
To the extent our processing of your personal information is based on your consent, you also have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the receipt of such withdrawal.
For additional GDPR related queries, or if you need any help with GDPR questions, please contact us at: DPO@virginmedia.co.uk