The protection and security of your personal data is important to The Condé Nast Publications Ltd (“the Company”). The purpose of this Information Notice is to make you aware of how we collect, use, share, and protect your personal data. The Condé Nast Publications Ltd of Vogue House, Hanover Square, London W1S 1JU is the controller of your personal data.
This notice does not form part of any employee’s contract of employment and we may amend it at any time.
1. Personal data collection
We may collect and process the following categories of personal data about you:
- Personal details (such as name, date of birth, gender, place of birth);
- Contact details (such as home address, e-mail addresses, telephone number);
- Family and social details (such as marital status, next of kin and relationship, emergency contact details);
- Education and training details (such as educational and vocational training);
- Employment details (such as employment history, performance ratings, details of any disciplinary actions, contract length, annual leave and sick leave details);
- Financial details (such as salary information, benefit information, bank account details, pension payment details and tax details); and
- IT details (such as Company property issued, IT access codes, IT usage data, IT login data and incident data, electronic message communication details, service requests).
We may receive this personal data directly from you, for example if you apply for a job with the Company via the careers page on our websites, and through new starter forms completed when joining the Company. We may also receive this information from third parties, such as recruiters, including personal data located CVs and job application forms.
Where required by local laws, or in connection with specific roles, we may collect and process special categories of personal data about you. Such special categories of personal data include racial or ethnic origin health data, criminal background data. These special categories of personal data will be processed to meet the Company’s legal responsibilities, or, where necessary, for personnel management and administration. Where required by local law we will obtain your explicit consent to process special categories of your personal data.
2. Purposes for processing your personal data
We process your personal data:
- for the performance of your contract of employment and to take initial steps to enter into a contract of employment during the recruitment and application stage;
- to comply with local EU laws, for example in relation to local tax requirements; and
- to fulfil our legitimate business interests, including for the operation of standard business functions
such as human resource management, legal and/or regulatory compliance and/or administrative and
managerial purposes, including without limitation:
- appraisals and performance;
- promotion, succession planning and talent management;
- training and development;
- pay, remuneration and expense reimbursement;
- administration of pension, insurance and other benefits;
- tax and other deductions from pay;
- managing corporate travel arrangements;
- health and safety;
- disciplinary, grievance and termination processes;
- monitoring the Company’s commitment to equality and diversity;
- assessing conformance with Company policies;
- maintaining and monitoring usage of internal networks and Company IT systems in line with Company guidelines and policies;
- regulatory compliance and investigations; and
- legal proceedings (including prospective legal proceedings), and the obtaining of legal advice, to protect the Company against damage, injury, theft, legal liability, fraud, abuse or other misconduct.
3. Data retention
We retain the personal data of unsuccessful candidates for the period of the application process and for longer when it is within our legitimate business interests to retain such data, for example to inform you of any future relevant job opportunities. We retain the personal data of employees for at least the period of the employment relationship. Once the period of your employment with the Company is terminated we will retain your personal data for as long as is necessary to comply with local labour laws and any other applicable laws and regulations, and for the purposes of our legitimate interests, as listed above.
4. Disclosure of your personal data
In connection with the purposes described above, we may need to transfer or disclose your personal data to the following categories of recipients:
- Other companies within the Condé Nast group
- Third party service providers that provide services to us involving data processing, including recruitment, payroll, security, communications, audit, accountancy, insurance, tax, pensions, medical, benefits, travel, mobility, transportation, employee education programmes, legal and other professional advisors.
- Third party business partners such as distributors, trade associations and events or conference providers where relevant to your employment role.
- Competent public authorities (such as tax authorities) where required by law.
- Trades unions, where required by law.
The Company reserves the right to transfer any personal data it has about you in the event that the Company sells or transfers all or a portion of its business or assets, without offering you the opportunity to opt-out of such transfer (except where required by local law). Should such a sale or transfer occur, we will use reasonable efforts to direct the purchaser or transferee to use employee personal data in a manner that is consistent with this Employee Information Notice.
5. International data transfers
We may need to transfer your personal data to a location outside of the European Economic Area (“EEA”), including to countries that do not offer the same level of protection with respect to personal data as required in the EEA, for example the United States. We have implemented appropriate safeguards, to protect your personal data, when it is transferred, including the execution of data transfer agreements with the recipients of the information.
For further information on, or a copy of, the adequate safeguards adopted by the Company for the international transfer of your personal data, please contact the Company by email at DataController@condenast.co.uk. We will process any request in line with any local laws and our policies and procedures.
6. Exercising your rights
You may have the right to request access to your personal data, to have it rectified or erased, to object to its processing or to have access to it restricted. You may also have the right to receive a copy of your personal data in a machine-readable format, to have your personal data sent to another entity or the right to not to be subject to any decision that significantly affects you being taken solely by automated processing, including profiling. We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you. Where permitted by law, an administration fee may be charged.
7. Contact us
To exercise any of your rights in connection with your personal data or if you have any questions or concerns as to the processing of your personal data, please contact your HR contact or line manager if you are an employee, or email@example.com if you are a job applicant. We will process any request in line with any local laws and our policies and procedures.
The processes described in this notice supplement any other remedies and dispute resolution processes which may be provided by the Company and/or which may be available under applicable local laws, including your right to lodge a complaint with a supervisory authority in your country.