Privacy and Cookie Notice for candidates to join the Diageo Group of Companies
1. Introduction and changes to this Privacy and Cookie Notice (PCN)
All references to 'our', 'us', 'we' or 'company' within this policy notice (the "PCN”) and within any consent notice are deemed to refer to Diageo PLC, its global subsidiaries, affiliates and associates.
We aim to protect your personal privacy. This PCN explains what we may do with any personal data that we collect from you, that you provide us or that is created because of your application.
We may need to update this PCN from time to time and any changes to this PCN will appear on this page. We therefore recommend that you check regularly the Career Site to ensure that you have read the most recent version of this PCN. This PCN was last updated on 1 November 2021.
2. Your consent to this PCN
By providing your personal data, you signify your acceptance of our PCN and are explicitly agreeing that Diageo processes, collects, uses and discloses your personal data as described in this PCN, including your sensitive (also known as special category) personal data.
2.2 Other legal bases for processing
You should be aware that we may also process your personal data based on grounds other than consent. For example, we may need to process your personal data to comply with a legal obligation. Alternatively we may need to process your personal data where there is a legitimate business objective (such as ensuring that we can recruit people to our business. However, we will take all reasonable steps to ensure that we only collect personal data that is necessary to achieve this objective and will not use it for any other purpose not envisaged in this PCN.
If you do not agree to any part of this PCN, you may choose not to provide us with your data or you can always withdraw your consent, although this may affect your ability to be considered for employment at Diageo. Please contact firstname.lastname@example.org if you have any questions. See section 9 – Your Rights and section 10 – Information on retention, unsubscribing, access, and any further questions.
3. What do we mean by personal data?
Personal data is broadly defined as any information which relates to an identified or identifiable individual. In the context of the Diageo Site for Applicants (“the Career Site”), such information may include, for example, your name, address, e-mail address, education and employment history.
4. Collecting and processing your personal data
In order to complete your candidate application process, Diageo collects personal data about you from your profile or CV as submitted by you to the Career Site.
By providing any personal data to us, you are confirming you are agreeing to the collection and processing of such information for the purposes described in section 6 (How we may use your personal data), including
- potentially entering into a contract of employment with you,
- potentially setting your employee profile into our internal technology support systems, for example pre-employment portal or Workday; and/or
- to comply with a legal obligation (amongst others).
5. Sensitive (also known as special category) personal data
Sensitive personal data is information as to an identifiable individual's:
(a) racial or ethnic origin;
(b) political opinions;
(c) religious beliefs or philosophical beliefs;
(d) membership of a trade union;
(f) sexual life and sexual orientation;
(g) genetic data or biometric data which is processed to uniquely identify a person
For the most part, we do NOT require you to provide sensitive personal data as part of our recruitment process, unless authorised by law or where necessary to comply with applicable laws.
However, in some circumstances (and where permitted by law), we may need to collect, or request on a voluntary disclosure basis, some sensitive personal data for legitimate recruitment-related purposes. For example; information about your racial/ethnic origin and gender, to enable us to monitor and promote equality and access to opportunities. You may provide, on a voluntary basis, other sensitive personal data during the recruitment process.
Where you voluntarily provide us with information on your gender or racial/ethnic origin during the application process, the information you provide will be used only on an aggregate basis for internal reporting for the purposes of equal opportunities monitoring.
6. How we may use your personal data
Once we have collected your personal data through the application process, we may use and/or disclose it in one or more of the following ways. These either fall under ‘Legitimate Interest’ or ‘Required for Legal Compliance’:
6.1 Recruitment Opportunities - We may use your personal data in order to consider you for recruitment opportunities within Diageo.
Additionally, if you set up our "Job Search Agent" or otherwise asked us to do so, we may also consider you for positions which we feel, from your application, you may be suitable for and which may interest you. (See section 10 – Information on retention, unsubscribing, access, and any further questions).
6.2 Informative Communications – If you have consented, we may use your personal data in order to communicate with you about news, information and opportunities at Diageo, including about our business, functions, roles, brands and our people
(see section 10 – Information on retention, unsubscribing, access, and any further questions).
6.3 Analysis - We may use information for internal recruitment and marketing analysis, for example, to assess trends amongst our potential staff or to measure the amount of traffic to our websites. Where you have voluntarily disclosed to us sensitive personal data (such as information regarding your gender or racial/ethnic origin) during the application process, we may use this information for internal analytics reporting on an aggregate basis, in order to monitor and improve diversity and reduce potential bias during our recruitment process. We may also provide this information to certain third party agencies acting on our behalf, for example those who assist us with recruitment or evaluate the effectiveness of our recruitment service, where applicable. We may also use your personal data analytics or benchmarking activities on an aggregated or statistical level to support the company’s legitimate business interests and performance and to improve the servicing offering overall to employees. We may also share non-personal data with others, such as our service providers and advertisers, in aggregate anonymous form, which means that the information will not contain any personal information about you.
6.4 Sale or Transfer - In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, financing, reorganisation or liquidation of any part of Diageo Plc, we may transfer or assign to third parties information concerning your relationship with us, including personal information that you have provided to us.
6.5 Legal purposes - We may collect, use and/or disclose your personal data if permitted by law or required to do so by law or where we believe such action is necessary in order to detect, protect or defend us and/or other third parties against regulatory action, error negligence, breach of contract, theft, fraud and other illegal or harmful activity, to comply with our audit and security requirements, to audit our Diversity agenda and Equal Opportunities ambition and to audit compliance with or corporate policies, procedures, legal and contractual obligations.
6.6 Transfer outside of the European Economic Area – We may transfer your personal data to other Diageo entities anywhere in the world as required for the uses identified in this PCN. In particular, the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"), including members of our Group located in our shared service centres in India, Latin America, and Africa.
It may also be processed by staff operating outside the EEA who work for us, for one of our suppliers or one of our third-party agencies.
For example, if you have applied in the UK for a job in South Africa we will need to transfer the information to our local HR team in South Africa. The countries which we transfer data to may not operate an equivalent level of data protection standards although we confirm we will take reasonable steps to ensure that your personal data is treated securely and in accordance with this PCN and Data Protection Legislation.
This includes having agreements in place with our service providers and / or other recipients of your personal data to ensure the security of your personal data.
7. Disclosure of personal data
In addition to disclosures required for the uses identified above, from time to time we may disclose personal data where it is necessary to our service providers and subcontractors, including our affiliates and associated subcontractors, retained to perform functions on our behalf including e.g., psychometric testing, personal development assessments, video interviews or to provide services to us in relation to the recruitment process.
Additionally we may need to share for the following purposes (by way of example only) data processing; software development;, HR enterprise system; website hosting and management; information technology and office services; legal, accounting, audit and other professional service providers and any other third party where required by law.
We take the security of your personal data seriously and have put in place appropriate technical and organisational measures designed to safeguard the information we collect and use. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.
We operate privileged access on users accounts via access security profiles, established via internal job profiles, so that only those teams who require to process your data will have access to it.
9. Your Rights
9.1 Your Rights EU/EEA:
Under Data Protection Legislation you have the following rights in relation to your personal data.
- If information about you is wrong or incomplete you can ask for this to be rectified
- You can ask for your information to be deleted (although this would mean that we would not be able to consider you for future employment opportunities)
- You can tell us you no longer agree to us using information about you and ask us to stop
- You can ask us to send you the information we have about you or ask us to send it to someone else through a subject access request by contacting email@example.com “Subject Access Request” in the subject line of the email or letter. It would be helpful if you could set out the reason for the requests and specify exactly what data you would like to see and the periods of time you are referring to.
You can ask us not to use information about you in a way that allows computers to make decisions about you e.g. automation and ask us to stop (although this would mean that we would not be able to consider you for future employment opportunities) If you have any privacy-related questions, concerns or complaints, please contact:
Post: Data Privacy Officer, Global Compliance Legal Team, 16 Great Marlborough Street, London, W1F 7HS
9.2 Non-EU/EEA rights
Different countries have a different approach to data protection. Some have rights very similar to the EU/EEA rights. Some have a data protection regime which are lighter touch, or which exist at a local level (such as the United States of America) and some countries have no data protection regime at all. We will comply with the relevant regime insofar as is possible. We suggest you send your request to us at firstname.lastname@example.org, or if writing by post at Data Privacy Officer, Global Compliance Legal Team, Diageo plc, 16 Great Marlborough Street, London, W1F 7HS
For India: You can send your request to us at:
Senior Counsel -Compliance
#24 Vittal Mallya Road, Bangalore,
email@example.comAM - 5PM (on all working days)
9.3 Right to escalate to a Regulator:
You have the right to complain about how we handle your personal data to the relevant regulatory body in your relevant jurisdiction; for example in the United Kingdom to the Information Commissioners Office (ICO).
10. Information on retention, unsubscribing, access, and any further questions
As part of our commitment to your privacy, we do not seek to hold your personal data for any longer than necessary.
Your personal data will be retained in accordance with Diageo's records retention protocols and based on relevant legal and business requirements. We do have a legitimate interest to hold your data for the purposes of confirming our response to any request to access or delete your data and for the purposes of requiring the information for legal defence implications.. This varies depending on which jurisdiction you are sitting in, but you can enquire how long by contacting firstname.lastname@example.org for further information.
You can ask us to have your personal data securely deleted prior to the expiry of the relevant retention period. If however you have asked us to keep you informed of new positions within Diageo on an ongoing basis, we will continue to retain your personal data to keep you updated on such opportunities until we are no longer using your personal data for this purpose.
11. Automated decision making
At different stages of the recruitment process; we may use automated means to select the favourable candidate for a role in our organization; using software technology, a candidate may be de-selected from the ongoing recruitment process on the basis of some of detail, specification or qualifications detailed in their application form or CV. This may be done to meet our legitimate interests or for legal requirements.
We will not carry out any automated decision-making on the basis of any sensitive personal data that you provide to us, such as information on your racial/ethnic origin or gender.
Cookies and similar technologies
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve your experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
For more information on how Diageo may use your personal data for these purposes please see the Diageo Privacy Cookie Notice and Conditions of Use.
Our site may, from time to time, contain links to and from the websites of our partner networks, and affiliates. 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 these policies. Please check these policies before you submit any personal data to these websites.
As required, this PCN will be supplemented by additional legal requirements in jurisdictions where we conduct business. Nothing in this PCN or otherwise will create, or add to, any right or claim (whether legal, equitable or otherwise) that any individual or person may have at law or otherwise against the company or any third party or any of their respective directors, officers, employees, agents or representatives (collectively the “Diageo Group”); nor will the existence of this PCN or its application impose or add to any obligations or liability upon the Diageo Group that the Diageo Group does not already otherwise have under law.