Let’s Talk about Privacy: Our Privacy Promise
Sky Bet is committed to protecting your privacy. We believe in using your personal information to make things simpler and better for you. We will always keep your personal information safe. We’ll be clear and open with you about why we collect your personal information and how we use it. Where you have choices or rights, we’ll explain them to you and respect your wishes.
This notice explains how we obtain and use your information when you apply for a job with us. Please take a few minutes to read it before submitting your application or CV. To make things quicker and easier, we’ve pointed out with a‘!’ some things we particularly need to bring to your attention as you may not be aware of them.
Who’s In Control of Your Information?
The information we collect during the recruitment process is held and used by Hestview Limited, one of the companies that make up our group. Where we use ‘we’, ‘us’, ‘our’, ‘Sky Bet’ or ‘Sky Betting and Gaming’ in this document, we mean Hestview Limited.
In the UK, to comply with local data protection law, Hestview Limited is registered as a ‘Data Controller’ with the Information Commissioner’s Office (ICO) and details published on a public register at https://ico.org.uk.
In Italy, to comply with local data protection requirements, our employees are designated ‘Incaricati Del Trattamento’ on behalf of the company and they, like all our employees in all our locations across all our brands, are required to complete regular data privacy training and comply with internal policies when handling personal information, whether that’s about customers, employees or potential employees.
As a UK-based organisation we’re governed by European data privacy law, principally the EU General Data Protection Regulation. This provides a privacy framework similar to that required by the Australian Privacy Act 1988, and ensures that potential employees living in Australia can be confident that we handle their personal information in a way that complies with the Australian Privacy Principles.
Our Data Protection Officer
Our group has a Data Protection Officer, responsible for ensuring that we comply with applicable data privacy law and regulation across our business. She can be contacted at firstname.lastname@example.org if you have any concerns about how we handle your personal information or about this notice.
The Information we hold about you and where it comes from
Information we get from you
Most of the personal information we hold comes from you directly (e.g. contact details, previous employment.) or indirectly (e.g. things you tell us in an interview). However, if you have applied through a recruitment agency they may give us your basic details, and if you’re with us on a university internship we may have some information supplied by your university. Please note that if you’re applying through our website, you must apply in person – we don’t accept third party referrals through this route.
! Information we get from social media
Social media is a great way of finding people, and if our recruitment team has approached you about a vacancy, we may have obtained your contact details from sites such as LinkedIn or Facebook, together with any publicly visible information about your skills or experience.
! Information we get from your device
We collect information from the device you use to visit our site and submit your application or CV, including IP address (a number that identifies a specific device on the internet and is required for that device to communicate with websites), hardware model, operating system and version, software, preferred language, serial numbers, device motion information, mobile network information and location data. We also collect server logs, which can tell us dates and times of access, content or pages viewed, crashes and other system activity and the website you were using immediately before visiting our site. We use this information to:
- Ensure that our site works properly for your device,
- Identify errors on the site
- Understand how people reach our site
- Assess the effectiveness of our site and its content
'Cookies' are small text files stored in your web browser that enable us to recognise your computer when you visit one of our websites. They are essential to keep our websites functioning correctly and securely, and we use them on our careers pages to:
- Enable you to move around the site and log into your account
- Deliver content in a way that works for the device you’re using
- Remember choices you’ve made and enable features such as password re-setting
- See how many people visit our website and which pages or features are most popular
- Identify whether and where people see error messages
! Information we get from Background Checks
We undertake pre-employment including credit reference and criminal record checks, address verification, confirmation of academic or professional qualifications, and requesting employer or other references. Experian carries out the checks on our behalf and will contact you directly to obtain your consent and ask you for any additional details. Experian provides us with only the outcome of the checks, to help us decide whether to go ahead with your employment.
We, or Experian acting on our behalf, may also check the details you give against fraud databases. If you have submitted fraudulent information in your application we will record this on those databases, where it will be available to other organisations including potential employers and law enforcement agencies.
Where you provide us with documents proving your eligibility to work in a particular country, we use them for that purpose only. We upload a copy of the documents to Experian, which carries out the necessary checks and stores details in line with legal and regulatory requirements.
! Information from your customer account
Responsible gambling is at the heart of our business, and our responsibility extends to our employees as well as our customers. We want our people to enjoy the products they help to create, but we need to ensure they do so in a way that doesn’t put them, or our business, at risk.
If we offer you a role, we will look at any information we hold about you as a customer of any of our brands (currently Sky Betting & Gaming, Sky Bet, Sky Vegas, Sky Casino, Sky Bingo, Sky Poker, Sky Games, Sky Sports Super 6, Sky Sports Fantasy Football, Fantasy Six a Side, Pick 7, SkyBet Italia, Oddschecker and Sportinglife) to identify signs that could indicate problem gambling. If we find such indicators, we will talk to you about the sources of help available to you, and in some cases may place restrictions (over and above our standard rules for the use of employee accounts) on the way you’re permitted to use your account once you’re an employee. We will always do this as sensitively as possible, with the information known only to those directly involved in making decisions about your role and/or about responsible gambling and risk.
Protecting our employees and our commercial interests is an important part of running our business effectively and efficiently, and is in our legitimate interestsas a business and an employer.
! How we use your information
As you’d expect, we use your personal information to keep the recruitment process running smoothly from end to end.
Our team will use the contact details you have provided to get in touch with you by phone, e-mail, post or SMS about the recruitment process and your application. Please let them know if you do not wish them to use a particular method of contact, and remember to ensure that the contact details you give us are sufficiently private to receive information about your application.
Like all employers we need to comply with a range of legal and regulatory obligations such as employment law, diversity and equality and health and safety rules. To fulfil the range of requirements and obligations, we hold your information for 2 years after an unsuccessful application. During that time, we will also review your details against other roles that come up and contact you about any vacancies that we think might interest you, but if you’d prefer us not to do that please let our recruitment team know. Meanwhile, if your application was successful, the details we hold about you on our recruitment system will form the basis of your future employee record.
Where we need to carry out reporting or statistical analysis about our recruiting process, we anonymise the data so that it can’t be linked back to an individual.
More Sensitive information
If you tell us about a disability or long-term condition, we’ll use that information only to make any appropriate adjustments in our interview/application process and, if you are successful, in your new work environment.
Information you provide via our Equality and Diversity questionnaire about ethnicity, gender, sexuality, religion or disability is used only to help us fulfil our diversity and equality monitoring requirements and is not held in a way that allows it to be linked to you. You will always have a choice about whether to provide this information.
How we Share your information
Like most organisations we use external companies to carry out some aspects of our business, as well as systems and tools provided or hosted externally. Where personal information is processed by a third party, we carry out checks to ensure that they will give it the same level of care and protection as we do. Both we and they are obliged to handle your information in accordance with data protection law, and we are required to put in place contractual measures reinforcing those obligations.
Where personal information is transferred outside Europe we put in place additional legal protections to ensure it receives the same level of protection as it would within Europe. We do this by using standardised contractual clauses (sometimes called ‘the EU Model Clauses’) approved by the European Commission and European privacy regulators, although there are alternative approved legal mechanisms which we can decide to use instead. Where necessary, we’ll also put in place any additional contractual measures required by local law or regulation in any of the countries in which we operate, except (within the EU) where they conflict with the General European Data Protection Regulation. If you would like to know more about the EU ‘Model Clauses’ or the requirements companies like Sky Bet have to fulfil when transferring personal data overseas, you can find information here.
Your details are held on systems hosted by Workday Corporation, and our SkybetCareers.com website is hosted by external companies (ChatterCommunications Limited; Phenom People Inc.) which also provide customer relationship management (CRM) functionality. Other third parties which may process personal data during the recruitment process are Experis (contractor recruitment), Attlassian and Slack (both workflow management), We Are Wiser Ltd (graduate recruitment) and Bolser (employee onboarding). Personal information is held and processed both within and outside Europe.
Other than as set out in this document, we do not share your personal information with third parties unless we are compelled or permitted by law and we have received a warrant, court order or other legally valid proof of authority.
Your Data Protection Rights
The right to have errors and inaccuracies corrected
If you’ve created an online account on SkyBetCareers.com, you can log in at any time and update your own details. If there is something you cannot correct yourself, you should contact the recruitment team and we’ll update inaccuracies within a month. If we take the decision not to make a change you have requested, we will explain why and make a note on your account to show that you requested it.
Your right of erasure (sometimes referred to as the ‘right to be forgotten’)
You have the right to request erasure of your personal data where our original purpose for collecting the data has been completed and we have no other valid legal grounds for continuing to hold it. As explained above, we hold your details for a period of time after your application to enable us to fulfil our legal and regulatory requirements and deal with any queries. As these are valid reasons to hold it, we won’t normally delete your information earlier unless a court or a regulator orders us to do so.
This right does not apply to potential employees living in Australia.
Your right to see the data we hold about you
If you would like a copy of the personal information we hold about you, you should request it here. We will ask you to complete a form, which is not compulsory but helps us to provide any specific information you are looking for. We will also ask you for valid proof of identity and once we’ve received it we’ll provide our response within one month.
Your right to “Data Portability”
The right to ‘Data Portability’ is a new initiative from May 2018 that aims to enable consumers to re-use some of their personal information online by making it available in a commonly-used, machine-readable format that can be passed to and used by other organisations. At the moment, this is unlikely to be useful in the context of recruitment and employment, and it is not currently possible to ‘port’ data directly between organisations. However, if you do wish to exercise this right, you should submit your request here, and we will provide you with a CSV file containing the personal details you gave us online during your application. We will ask you to provide valid proof of identity, and will provide our response within one month of receiving it.
This right does not apply to potential employees living in Australia
Your right of objection to certain types of processing
As this notice explains, most of the things we do with your personal information are necessary in order to progress with your application, and some are necessary to meet our legal obligations. There are a couple of activities that fall outside those two categories but which are still important and which we have a legitimate interest in doing as a business. Data Protection law gives you a right to object to activities that fall into this category if your rights and freedoms outweigh our legitimate business interest. They are:
- Our use of Information from your customer account. As we explain, it’s important both for you and for us that we work to minimise the risks associated with problem gambling, and we do this in a sensitive and proportionate way. We can’t recruit you without doing this, so if you do wish to exercise your right to object, your option will be to withdraw, or not to submit, your job application.
- As describedhere, we review your information to see if you’re suitable for future vacancies. We believe this can benefit both you and us and we hope you agree, but if you do not wish us to do this, simply contact Careers@skybettingandgaming.com
Privacy Rights in Australia
European privacy law gives people some rights that go beyond those in Australian privacy law, so some of the rights listed above (the rights of objection, of data portability, of objection and of erasure) do not apply to you if you’re living in Australia. However, your privacy is just as important to us wherever in the world you are so we’ll always try to accommodate reasonable requests if we can. If you have a concern about your privacy rights, please let us know.
Your Right to Complain to the Regulator
If you believe your privacy rights have been infringed, or you disagree with a decision we have made about your personal information, you have the right to complain to the privacy regulator. We are based in the UK, so our lead data protection regulator is the UK’s Information Commissioner‘s Office (ICO), which may be contacted at https://ico.org.uk, but if you are any other country in the EU you may prefer to initiate contact through the regulator in your country of residence:
- In Germany: www.bfdi.bund.de
- In Italy: www.garanteprivacy.it
- In Malta: https://idpc.org.mt/en/Pages/Home.aspx[LW4]
European data privacy law provides a privacy framework similar to that required by the Australian Privacy Act 1988, but if you are in Australia and have any concerns about how we handle your personal information, you can contact the Australian Information Commissioner at www.oaic.gov.au.