Privacy policyOUR PRIVACY PROMISE We take your privacy seriously and we respect your privacy and data protection rights. This privacy notice aims to give you information on how we collect and process your personal data through your use of our website, mobile apps and our services, including any data you may provide through our websites, and our services when you sign up to receive news, offers, promotions and updates, book a table with us, take part in a competition, complete a survey, provide feedback, use our Wi-Fi, mobile apps or otherwise purchase a product or service (such as buying a gift card). Please take time to read this privacy notice in full, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, to ensure that you understand and are happy with how we collect and process your personal data. This privacy notice supplements the other notices and is not intended to override them. We sometimes collect and process Sensitive Data (such as your health information, race, ethnicity) and Children’s Data. See sections 6 and 7 of this Privacy Policy for details. Except where set out to the contrary in another of our privacy notices (for example, our Candidate Privacy Notice for job applications), we do not collect or process any information about criminal convictions and offences.
1. CONTROLLER Middletons Steakhouse & Grill is a trading name of Gastro Pubs Ltd. This privacy notice is issued by Gastro Pubs Ltd (company number 05781605 with its registered office at The Crown Inn, Lynn Road, Middleton, King's Lynn, Norfolk, United Kingdom, PE32 1RH) so when we refer to “we”, “us” or “our” in this privacy notice, we are referring to Middletons Steakhouse & Grill. Gastro Pubs Limited is the controller and is responsible for our websites and this service. We have appointed a data protection officer (DPO), who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details below:
2. CONTACT DETAILS Our full details are: Data Protection Officer Lynn Road, Middleton, King's Lynn, Norfolk, United Kingdom, PE32 1RH You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the supervisory authority for data protection issues in the UK (phone: 0303 123 1113 or at www.ico.org.uk/concerns). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance.
3. CHANGES TO THIS PRIVACY NOTICE AND CHANGES TO YOUR DETAILS We will need to update this privacy notice from time to time as the law and/or our business changes and develops. We will endeavour to tell you in advance by sending a service message to you if we hold your email address. Otherwise, please look out for the flags on our websites and materials that indicates we have changed this privacy notice. If you continue to use our websites and/or services after we have changed our privacy notice, we will take this as an indication that you accept the changes. It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
4. THIRD PARTY LINKS Our websites, mobile apps and/or the service may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, mobile app and/or service, we encourage you to read the privacy notice of every website, plug-in and/or application that you visit.
5. THE PERSONAL DATA WE PROCESS Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may process different kinds of personal data about you, which we have categorised as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
6. SENSITIVE DATA In certain situations we have to collect Sensitive Data about you. Under data protection law this is known as “special category” data and includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health and genetic and biometric data. When do we process Sensitive Data? We only collect and process Sensitive Data where you provide such information to us in the following situations:
7. CHILDREN’S DATA Children need particular protection where their data is collected and processed. We may collect and process Children’s Data in certain situations as described below. When do we process Children’s Data? We only collect and process Children’s Data in the following situations:
We are allowed to process Children’s Data where it is required for our legitimate interests (offering and hosting children’s parties and other events in our venues, dealing with feedback and complaints, understanding how customers interact with our mobile apps and websites, providing safe and secure use of our online facilities) or whenever required to comply with a legal obligation; and, in any of these situations, where the processing is necessary. Alternatively, or in addition, we may process Children’s Data on the basis of consent, given or authorised by the holder of parental responsibility (and in these circumstances we will always make reasonable efforts to verify such consent).
8. PROFILING We do, from time to time, process personal data about you in an automated way to evaluate certain personal aspects about you, including to enable us to analyse and make predictions about your interests and how you are likely to interact with our Company. This is commonly referred to as profiling and it is our way of providing you with a more bespoke customer experience based on how we think you engage with us and our Company. The personal data about you that we process for profiling purposes includes your Identity Data, your Contact Data and your Profile Data. We do not process personal data about you for profiling purposes that consists of Special Category Personal Data. We process your personal data for profiling purposes for our legitimate interests as set out below if you would like to learn more about exactly the kind of profiling we do and what profiling means to you. You also have the right to object to us processing your personal data for profiling; to learn more about your right to object, see section 15. HOW WE PROFILE AND THE LOGIC WE USE We collect your personal data from several sources, including directly from you, which we then combine in order to create a view of your interactions with our group of companies. Once we have this record, we match multiple variables that are unique to you (such as name, email, postcode and/or mobile number) to create an overall matched record. We then clean the record by comparing it with certain third-party reference files (such as the Post Office Address File, the Bereavement Register and email validation) to try to ensure that the record is as accurate as possible. Once the record is cleaned, we add the record to our customer database and we start to build a behavioural profile about you, which details the brands that you do, or do not, engage with. We also infer a visit to a particular brand location so that we can gain a better understanding of how far you might travel to visit a particular brand of ours. In addition, we apply our algorithms or scoring models to the record to indicate how likely it will be that you will visit a particular brand in the future. We then segment our overall database to create a customer base for each brand to determine those customers with a high likelihood to visit a brand and those who are unlikely to visit a brand. Your record may be in more than one segmented element of the database, for example, you may be high likelihood for 3 of our brands and low likelihood for 2 of our brands within your catchment area. As well as looking at how you interact with our brands, we also apply demographic profiles (provided to us by a third party supplier of demographic data) to your record using your postcode. These profiles are trends based on a nationally representative sample. This enables us to understand your likely profile such as age, home and financial situation as well as your attitudes to family, home life, matters such as dining, media consumption or your purchasing behaviour. Finally, to ensure that you get the most relevant communications from us, we may use the above variables (if you have agreed to us sending you certain communications) to select an appropriate communication for you to receive, as well as ensuring the you receive the right content or offer. For example, our profiling will help us determine whether you may be more interested in a family message and offer as opposed to a champagne promotion. We enhance this information with data we have regarding the communications and promotions that you have (or have not) engaged with in the past.
Significance and Consequence of the Profiling The profiling we do enables us to better understand how you interact, or may interact, with our brands. It enables us to provide you with the most relevant information (such as vouchers and offers where you have agreed to receive these) and to determine whether a particular brand or outlet should be more tailored to those people who do, or who are likely to, visit it. The profiling also helps us to improve our services and the offerings of our brands depending on the demographic of existing or future visitors.
9. HOW WE COLLECT YOUR PERSONAL DATA We use different methods to collect personal data from and about you including through:
10. HOW WE PROCESS YOUR PERSONAL DATA We only process your personal data when allowed to do so by law. Most commonly, we will process your personal data:
The below table sets out how we process your personal data. Please contact us if you would like further information about the specific basis for processing. 10A - Activity:
Personal Data
Basis for Processing
10B - Activity
Personal Data
Basis for Processing
10C - Activity
Personal Data
Basis for Processing
10D - Activity: Personal Data
Basis for Processing
10E- Activity:
Personal Data
Basis for Processing
10F - Activity:
Personal Data
Basis for Processing
10G - Activity:
Personal Data
Basis for Processing
10H - Activity: To provide information to legal and regulatory bodies where we are under a legal or regulatory obligation to do so. Personal Data
Basis for Processing
11. HOW WE SHARE YOUR PERSONAL DATA We cannot run our business or provide many of the services and benefits you expect to receive without involving other people and businesses. We only share your information in accordance with the laws applicable to us and for the purposes set out in the table in paragraph 8 above. We share your personal data with:
12. INTERNATIONAL TRANSFERS Some of our external third parties are based outside of the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data outside of the EEA, we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
If you have any questions in relation to this section, please contact pr@middletons-shg.co.uk .
13. HOW WE KEEP YOUR PERSONAL DATA SECURE We take the security of your personal data very seriously and have in place appropriate security measures at all times, including where we share your information with our suppliers and partners, to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Please take care of your own information. For security tips and tricks when using the internet, Wi-Fi and smartphones or tablets, please visit www.getsafeonline.org.
14. OUR RETENTION OF YOUR PERSONAL DATA We can only keep your personal data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise length of time we hold your personal data for varies depending on the individual circumstances, but in determining the appropriate retention period for personal data, we consider the 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 and whether we can achieve those purposes through other means, and the applicable legal requirements. We regularly review our retention periods to ensure that we are not keeping your data for longer than necessary. Details of retention periods for different aspects of your personal data are available by contacting us.
15. YOUR RIGHTS In certain circumstances, you may have the right to request access, transfer, rectification and/or erasure of the personal data that we process about you. You may also have the right to object to and/or restrict our processing of your personal data. Details of the rights are set out below.
To exercise any of these rights please contact us using the details in Section 2. The ICO regulates most UK data and information laws. To learn more about your rights, visit the ICO website at www.ico.org.uk
CANDIDATE PRIVACY POLICY
What is the purpose of this document? Middletons Steakhouse & Grill is a trading name of Gastro Pubs Ltd. This privacy notice is issued by Gastro Pubs Ltd (company number 05781605 with its registered office at The Crown Inn, Lynn Road, Middleton, King's Lynn, Norfolk, United Kingdom, PE32 1RH) so when we refer to “we”, “us” or “our” in this privacy notice, we are referring to Middletons Steakhouse & Grill. Gastro Pubs Limited is the controller and is responsible for our websites and this service. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, apprentice, 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).
Contact Details We have appointed a data protection officer (DPO), who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details below:
Data Protection Officer Lynn Road, Middleton, King's Lynn, Norfolk, United Kingdom, PE32 1RH You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the supervisory authority for data protection issues in the UK (phone: 0303 123 1113 or at www.ico.org.uk/concerns). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance.
Changes to this Privacy Notice and Changes to Your Details We will need to update this privacy notice from time to time as the law and/or our business changes and develops. We will endeavour to tell you in advance by sending a service message to you if we hold your email address. Otherwise, please look out for information on our websites and materials that indicates we have changed this privacy notice. If you continue to use our websites and/or services after we have changed our privacy notice, we will take this as an indication that you accept the changes. It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Data protection principles We will comply with data protection law and principles, which means that your data will be:
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:
We may also collect, store and use the following "special categories" of more sensitive personal information (Sensitive Personal Information):
How is your personal information collected? We collect personal information about candidates from the following sources:
How we will use information about you We will use the personal information we collect about you to:
It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role. We also need to process your personal information to decide whether to enter into a contract of work with you. Having received your CV and covering letter and/or your application and the results from any test that you take as part of the application process, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the 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, carry out a criminal record and/or carry out any other kind of check that we consider necessary before confirming your appointment.
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. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use Sensitive Personal Information We will use your Sensitive Personal Information in the following ways:
INFORMATION ABOUT CRIMINAL CONVICTIONS We will process information about criminal convictions. We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular when certain roles require a high degree of trust and integrity since they involve dealing with money and/or financial systems. In these circumstances, we would like to ask you for your criminal record history and/or your permission to seek a basic disclosure of your criminal records history. Where required by law, we have in place an appropriate policy document and safeguards which we maintain when processing such data.
Automated decision-making When you make an application online (for example by utilising the platform provided by Caterer.com or Indeed.co.uk) or when you complete certain assessments (for example, around situational judgements) we may utilise automated decision making to assess your application. We apply relatively simple processes (based largely on yes / no responses you provide us and pass/fail results) to create a short list of possible candidates. We need to do this in order to manage our recruitment process effectively and to ensure that all applicants that progress through the process meet our basic requirements for the role in question. The consequence of automated decision-making process will be to determine whether you proceed further in the recruitment process. More information regarding the questions that we may ask you that result in an automated decision being made are set out in the below table.
Question/Topic 1: It is a legal requirement for individuals to prove their eligibility to work in the UK. Documentary evidence of your right to work in the UK will be required before you commence employment. Which of the following applies to you?
Our Basis for the Automated Decision-Making Process Consequence for You
Question/Topic 2: Are you aged 18 or over?
Our Basis for the Automated Decision-Making Process
Consequence for You
Question/Topic 3: Are you of school leaving age?
Our Basis for the Automated Decision-Making Process
Consequence for You
Question/Topic 4: Have you accepted a Fixed Penalty Notice for serving alcohol to somebody under 18 years old during the last 12 months?
Our Basis for the Automated Decision-Making Process
Consequence for You
Question/Topic 5: Do you have any criminal convictions that are unspent under the Rehabilitation of Offenders Act 1974 (including drink driving offences)?
Our Basis for the Automated Decision-Making Process
Consequence for You
Question/Topic 6:
Our Basis for the Automated Decision-Making Process
Consequence for You
Question/Topic 7:
Our Basis for the Automated Decision-Making Process
Consequence for You
DATA SHARING Why might you share my personal information with third parties? We will only share your personal information with the following third parties for the purposes of processing your application, such as other entities in our group and certain providers that are acting for us as part of your application process (such as recruitment agents and recruitment related service providers. All our third-party service providers and other entities in the 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 data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Data security We take the security of your personal data very seriously and have in place appropriate security measures at all times, including where we share your information with our suppliers and partners, to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Please take care of your own information. For security tips and tricks when using the internet, Wi-Fi and smartphones or tablets, please visit www.getsafeonline.org.
DATA RETENTION How long will you use my information for? We can only keep your personal data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Unless you explicitly agree otherwise with us (for example, you wish to remain on our records for potential future opportunities for a longer period), we will retain your personal information for a period of 12 months after either we have communicated to you our decision about whether to appoint you to the role or you have deactivated any online account you may have with us in relation to applications (whichever is the latter). 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. After this period, we will securely destroy your personal information in accordance with our data retention policy. If we wish to retain your personal information on file for a longer period, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately to let you know that we intend to retain your personal information for a fixed period on that basis. You can contact us at that time or at any time afterwards to ask us to remove your information, and we will do so. We regularly review our retention periods to ensure that we are not keeping your data for longer than necessary. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. Under certain circumstances, by law you have the right to:
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 our Data Protection Officer in writing.
Right to withdraw consent When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise in certain ways that we made clear to you at the time we obtained your consent. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact our Data Protection Officer. 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.
|
Find out all you need to know before visiting us.