Recruitment Policy

1. Who are we?

We provide advice on all aspects of food law in the UK, EU and international markets, delivered in a clear, practical way to help companies find commercial solutions to labelling problems. Ashbury’s Head Office is based in Holborn, London. We have remote workers placed all over the world and we work on site with a variety of our customers.

Ashbury have an overall Privacy Policy, to which this Privacy Notice is supplementary. This Notice will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment. Any information we hold will be governed by the most current version of this Notice and our Privacy Policy.

Please read this Notice carefully.

2. What does this Notice cover?

We at Ashbury take your personal data seriously. This Notice deals specifically with the recruitment process, and:

  • sets out the types of personal data that we collect about you;
  • explains how and why we collect and use your personal data;
  • explains how long we keep your personal data for;
  • explains when, why and with who we will share your personal data;
  • sets out the legal basis we have for using your personal data;
  • explains the effect of refusing to provide the personal data requested;
  • explains the different rights and choices you have when it comes to your personal data; and
  • explains how we may contact you and how you can contact us.

3. What personal data do we collect about you?

We collect the information necessary to match your eligibility with our available opportunities for employment. This information may include: your name, private and corporate email address, postal address and telephone number, curriculum vitae, work history, your educational records and training, work performance and right to work, compliance and identity documentation, references and links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

Depending on the nature of our role an individual may be considered for, and also depending upon the applicable jurisdiction, we may need to collect and process sensitive personal data about you which may include information about your health (including details of any sick leave taken during your previous roles), details of any disability, details of any offences you have committed or are alleged to have committed.

4. Where do we collect personal data about you from?

 The following are the different sources we may collect personal data about you from:

  • Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages. For example, by filling in candidate registration forms in person or on websites.
  • From an agent/third party acting on your behalf. For example, this may be your own limited company or from another recruitment business or agency where you are applying to work for Ashbury.
  • Through publicly available sources with professional relevance. We use the following public sources:
    • Professional social media and networking sites (including LinkedIn)
    • Job Boards that you have registered your details on
    • Online curriculum vitae libraries
    • Corporate websites
    • By reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer or we may get a reference from your previous employer or a named referee included on your application form or curriculum vitae.

5. How and why do we use your personal data? 

We use your personal data so that we can recruit you for employment.

This includes:

  • Carrying out our obligations arising from any contracts we intend to enter into or have entered into between you and us;
  • Providing you with information about job vacancies and to assist you in finding a suitable position (either temporary or permanent) by matching your skills, experience and education with our available roles. We will initially collect basic information on you such as contact details, job role and experience and then pass this onto relevant managers and varying members of our Human Resources team. If you successfully move through to the next stage, we will then be collecting more information from you at the interview (or equivalent) stage and onwards in that manner;
  • Managing a temporary or contract assignment – if you are engaged by Ashbury as a temporary worker;
  • Notifying you about changes to our services, this Notice or our Privacy Policy;
  • Complying with our legal obligations and rights, under contracts and at law, and to cooperate with authorities and investigations.

6. How long do we keep your personal data for?

We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations.  We retain your information gained through the recruitment process for a minimum of one year. This is necessary to meet our legal obligations under Equal Opportunity law. Details on specific retention periods can be obtained by contacting us.

When determining the relevant retention periods, we will take into account factors including:

  • our contractual obligations and rights in relation to the information involved;
  • legal obligation(s) under applicable law to retain data for a certain period of time;
  • our legitimate interest where we have carried out a balancing test (see section 8 below);
  • statute of limitations under applicable law(s);
  • (potential) disputes;
  • if you have made a request to have your information deleted; and
  • guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information once this is no longer needed.

7. Who do we share your personal data with?

Your personal data may be shared with certain third parties who will be subject to contractual obligations of confidentiality and compliance with relevant laws, including:

  • Our employees who have a position to fill, in order to determine whether you are a good fit for the available position.
  • From an agent/third party acting on your behalf. For example, this may be your own limited company or from another recruitment business or agency where you are applying to work for Ashbury.
  • Prospective partners such as clients, if it is likely that you could be based on client sites.
  • If required to do so by law, a court order or by a regulatory authority of competent jurisdiction or if we believe that such action is necessary to protect, defend or enforce the rights of Ashbury.

8. What legal basis do we have for using your information?

For applicants and candidates who are applying to work for Ashbury, our processing is most commonly on the basis that such processing is necessary for our legitimate interests. To maintain, expand and develop our business we need to record the personal data of prospective candidates.  The exchange of personal data of our candidates and our employee and client contacts is a fundamental and essential part of this process.  We need personal data to assess suitability for potential roles, to find potential candidates and to contact referees.

We will rely on the legal basis of processing personal data under a legal obligation if we are legally required to hold information on you to fulfil our legal and regulatory obligations, such as disclosure to public authorities, regulators and investigations.

If you are interviewed and submitted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. Such information may be required to perform/qualify for a certain function for which you want to apply based on national laws, which may provide the legal basis to process these data. In cases where there is no other legal basis, we will ask for your express consent orally, by email or by an online process for the specific activity we require consent for and record your response. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time (as set out in section 16 below).

9. What happens if you do not provide us with the information we request or ask that we stop processing your information?

If you do not provide the personal data necessary, object to or withdraw your consent (where applicable) for the processing of your personal data, we may in individual cases not be able to match you with available job opportunities.

10. Do we make automated decisions concerning you?

No, we do not carry out automated profiling as there is human intervention in all our processing of personal data.

11. Security and storage of your data

Safeguarding personal data and respecting confidentiality of your information is important to Ashbury.

All information you provide to us is stored securely and we take necessary steps, including putting in place appropriate technical and organisational measures, to protect your personal data.

12. Using our websites – internet-based transfers

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our website includes links to external websites operated by other organisations which may collect personal data about you when you visit them. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for the privacy practices of any third-party websites. Please check these policies before you submit any personal data to these websites.

13. Do we use Cookies to collect personal data on you?

Ashbury does not use Cookies to collect personal information.

14. IP addresses

We may collect information about your computer including where available your IP address, operating system and browser type for system administration and to analyse visitor trends and traffic on our website. This information is collected in aggregate form and does not identify individuals. It is not passed on to third parties.

15. What rights do you have in relation to the data we hold on you?

By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from us using the contact details at the end of this Notice or the data protection regulator in your country.

Your rights and what they mean (please note that these are general summaries only; please contact us or the data protection regulator in your country for further detail):

  1. The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Notice.

  1. The right of access

You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Notice and our Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.

  1. The right to rectification

You are entitled to have your information corrected if it’s inaccurate or incomplete.

  1. The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

  1. The right to restrict processing

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

  1. The right to data portability

You have rights to obtain and reuse your personal data for your own purposes across different services.

  1. The right to object to processing

You have the right to object to certain types of processing, including processing if you no longer want to be contacted with potential opportunities.

  1. The right to lodge a complaint

You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

  1. The right to withdraw consent

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful).

Please consider your request responsibly before submitting it. We will respond within one month from when we receive your request.

16. Keeping our records accurate and up to date

Ashbury will review the personal data it processes to ensure that it is up to date and accurate. Your co-operation in helping us to keep your personal data accurate by informing us of any change of name or change of address is an important part of this. If you would like to review or change the details you have supplied us with, you may do so at any time by notifying us in writing.

17. Changes to this Notice

This Notice was last updated in May 2019. Ashbury may change this Notice from time to time. If we change our Notice, we will post the changes on our website and, where appropriate notify you by email. The date of issue will be indicated. We recommend that you check the terms of this Notice periodically to keep up to date with any changes.

 18. How will we contact you?

We may contact you by phone, email or social media. If you prefer a particular contact means over another, please just let us know.

19. How can you contact us?

If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us here: Tanya.Hart@ashburylabelling.co.uk or by phone (+44) 203 892 2646.