This notice describes how IAG Loyalty ("IAGL", "we", "us" or "our") uses your personal data in
connection with your application for employment with us. It also describes your data
protection rights, including a right to object to some of the processing which IAGL carries out.
More information about your rights, and how to exercise them, is set out in the "Your choices
and rights" section.
We also may provide you with additional information when we collect personal data, where
we feel it would be helpful to provide relevant and timely information.

• Personal identification and communication information: your name, home address, phone number; email address; date of birth, gender, immigration status, and
  information about your entitlement to work;
• Application-related information: curriculum vitae (CV), cover letter, employment history, education history, qualifications and skills, reference contact information, position preferences, willingness to relocate, desired salary, right to work information, interests and aspirations and background screening information if relevant; and
• Sensitive information: for example, information about your health and disabilities where we need to make any reasonable adjustments. 

We collect, use and store your personal data for the reasons set out below.

• Where this is necessary for IAGL to enter into an employment contract with you:
  • To make informed decisions on recruitment and assess your suitability for the role;
  • To communicating with you about your application, to respond to your inquiries and schedule interviews;
  • To reimburse you for any agreed expenses incurred in the application process where applicable.

• Where necessary for IAGL's legitimate interests, as listed below, and where our interests are not overridden by your data protection rights:
  • To improve our recruitment process and activities;
  • To verify the details you have supplied and, where applicable, conduct preemployment background checks;
  • Protecting our legitimate business interests and legal rights, including, use in connection with legal claims, compliance, regulatory, auditing, investigative
    and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance
    reporting requirements;
  • To analyse and monitor the diversity of the workforce in accordance with applicable laws. This includes, for example, compliance with equal opportunity
    employment laws.
• Where we process personal data on this basis, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals interests outweigh our interests in the processing taking place.
• Where necessary to comply with a legal obligation.
  • To assess your fitness and propriety in connection your engagement in a controlled function, where applicable;
  • To comply with legal, regulatory and other requirements under EU or Member State laws.
• Where you have given consent:
  • To contact you about future career opportunities at IAGL.

We may provide you with more specific notices for some of the processing described above and, if we require your consent, will ask for this at the time we collect your personal data.

For certain positions, it will be necessary for us to verify the details you have supplied (for example, about your identity, employment history, academic qualification and professional credentials) and to conduct pre-employment background checks (for example, in relation to previous criminal convictions or financial standing). The level of checks will depend on your role, in particular whether you will occupy a regulated role, and will be conducted at as late a stage as is practicable in the recruitment process and often only after you have been selected for the position. If your application is successful, we will provide further information about the checks involved and will obtain any necessary consent prior to completing such checks.

Personal data will primarily be processed by employees in our People Team, IT and finance, and facilities departments.

Your personal data will be shared with companies providing services, such as technology services including hosting, maintenance, administration and analysis, as well as other agencies, under contract to IAGL as part of the recruitment process. For example, we may share your data with our third-party employment brand agency "Chatter". We also share your personal data with “Security Watchdog” a third-party background checking provider.

Your personal data also will be shared with government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.

In the event that an IAGL business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.

In the event that applicant data is otherwise transferred outside of the UK or the EEA to an organisation in a country which is not subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure your personal information is adequately protected (e.g. by way EU Commission approved Standard Contractual Clauses, or by relying on such other data transfer mechanisms as available under applicable data protection laws. A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.

You have the right to ask IAGL for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to IAGL processing your data, this will not affect any processing which has already taken place at that time.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority. In the UK, this will be the Information Commissioner.

Where we collect personal data to administer our contract with you or to comply with our legal obligations, this is mandatory and we will not be able to manage the employment relationship without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to participate in certain programs or systems, where the information is needed for those purposes.

If you are successful: we will retain your personal data only for as long as we need it for IAGL's legitimate interest in accordance with applicable law, for the purposes of the recruitment process and, once this process is finished, for an appropriate period so as to be able to deal with any legal claims linked to the application process. Recruitment records for successful applicants are generally kept for 6 years. After this period, we will take steps to delete your personal data or hold it in a form that no longer identifies you. If you become an IAGL employee, relevant personal information you provide will become a part of your employee file and may be used later for the management of the employment relationship.

If you are not successful: we will retain your personal data with your permission so we can keep you in mind for future recruitment processes; otherwise, it will be deleted after 6 months.

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

The data controller for your personal data will be IAGL.
If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us at data.protection@avios.com.