WHAT IS THE PURPOSE OF THIS DOCUMENT?  

Lottoland (including Daisy Services Limited and any affiliate or other legal entity within the Lottoland Group and referred to herein as either “Lottoland”, “we” and “our”) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

DATA PROTECTION PRINCIPLES  

We will comply with data protection law and principles, which means that your data will be:

• 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.

THE KIND OF INFORMATION WE HOLD ABOUT YOU  

In connection with your application for work with us, 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, employment history, skills, experience, qualifications.
• Any information you provide to us during an interview.
• Information about your current level of remuneration, including benefit entitlements;
• Information about your entitlement to work in the Gibraltar or another jurisdiction where you may be located.

We may also collect, store and use the following types of more sensitive personal information:

• Information about your race or ethnicity or religious beliefs,
• Information about your health, including any medical condition, health and sickness records.
• Information about criminal convictions and offences.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?  

We collect personal information about candidates from the following sources:

• You, the candidate.
• Recruitment agencies
• Credit reference agencies
• Your named referees.

HOW WE WILL USE INFORMATION ABOUT YOU  

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

• Assess your skills, qualifications, and suitability for the role.
• Carry out background 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.

It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business.

We also need to process your personal information to decide whether to enter into a contract of employment with you.

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), we will not be able to process your application successfully or take your application further.

HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION  

We will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

INFORMATION ABOUT CRIMINAL CONVICTIONS  

We do not envisage that we will process information about criminal convictions, but we may need to, depending on the role that you are applying for i.e. the role requires a high degree of trust and integrity.

AUTOMATED DECISION-MAKING  

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

DATA SHARING  

Why might you share my personal information with third parties?

Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

Lottoland will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Lottoland will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

Lottoland will not transfer your data outside the European Economic Area.

DATA SECURITY  

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

DATA RETENTION  

How long will you use my information for?

If your application for employment is unsuccessful, the organisation will hold your data on file for 6 months after the end of the relevant recruitment process. If you agree to allow the organisation to keep your personal data on file, Lottoland will hold your data on file for a further 6 months for consideration for future employment opportunities. At the end of that period [or once you withdraw your consent], your data is deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new employee privacy notice.

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 particular 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 the HR Team on hr-team@lottoland.com

RIGHT TO WITHDRAW CONSENT  

In the limited circumstances where you may have provided your consent to us processing your personal information for the purposes of the recruitment exercise, you have the right to withdraw your consent for that purpose at any time. To withdraw your consent, please contact hr-team@lottoland.com

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 data securely.

DATA PROTECTION OFFICER  

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO dpo@lottoland.com . You have the right to make a complaint at any time to the Gibraltar Regulatory Authority (GRA), the Gibraltar supervisory authority for data protection issues.