Privacy & Cookie Policy

Lifeplus Europe Limited May 2018

Lifeplus Europe Limited Privacy Policy for Recruitment

Purpose

This Notice describes, as required by the General Data Protection Regulation (“GDPR”), how Lifeplus collects and processes your personal information, during your recruitment journey with us.

This Notice defines the data protection principles contained within the GDPR, what personal information we collect and hold about you and why, who we may share your personal information with and why, and your rights in relation to this information.

Introduction

We are Lifeplus Europe Ltd (“Lifeplus”). Lifeplus Europe is a data controller and a data processor. Our nominated representative for data protection and the purposes of the General Data Protection Regulation (EU/2016/679) is Sam Arnold. Our registered office is Lifeplus House, Little End Road, Eaton Socon, St. Neots, Cambridgeshire, PE19 8JH, England. We may be reached at T +44 1480 224610; F +44 1480 224611; email to info.eu@lifeplus.com.

On occasion, other companies within the Lifeplus group may handle personal information as a controller or processor.

Lifeplus is committed to protecting the privacy and security of your personal information. As a data controller, Lifeplus is responsible for deciding how and why your personal information is collected and processed. Lifeplus is required under data protection laws to notify you of the information contained in this Notice.

It is important that you read this Notice, together with any other notice or policy, (including the Privacy Policy) which we may provide you with on specific occasions when your personal information is being collected or processed, so that you are fully aware of how your personal information is being used by Lifeplus.

Scope

This Notice applies to all potential employees, workers or contractors, who have provided personal information either directly or indirectly (i.e. through a recruitment agency) to Lifeplus.

Definitions

“Personal Information” – Information is personal if it relates to an individual (a data subject) and an individual can be identified from that information. Examples of personal information include names, addresses, email addresses, telephone numbers, images, National Insurance numbers, banking and credit card details.

“Special Category Information” – Examples of special category information include racial or ethnic origin, political opinions, religious or other beliefs, trade union membership, genetics, biometrics, health, sex life and sexual orientation. Lifeplus Europe Limited May 2018

Data Protection Principles

Lifeplus is dedicated to complying with data protection law. This states that any personal information held about you must be:

1. Used lawfully, fairly and in a transparent way

2. Collected only for valid purposes that have been clearly explained to you, and not used in any way that is incompatible with those purposes

3. Relevant to the purposes for which it was collected, and limited only to those purposes

4. Accurate and kept up to date

5. Kept only as long as is necessary for the purposes for which it was collected

6. Kept securely

Types of Personal Information Collected and Held

Lifeplus is permitted to collect, retain and process the following types of personal information about you:

 Personal contact details such as your name, address, telephone numbers and personal email address

 Date of birth

 Gender

 Nationality

 Passport details, including a scan / photocopy for all potential employees

 Right to work documentation

 Location of current employment or workplace

 Any other recruitment information provided by you, to us, in a curriculum vitae (CV) or cover letter or online application, or received from a third party (such as a recruitment agency) as part of your application to Lifeplus

 Compensation information

Lifeplus may collect, retain and process the following types of special category information once an offer of employment, on any terms, is made:

Information about criminal convictions and offences

How Lifeplus Uses Personal Information

Lifeplus will only use your personal information, or special category information when there is a lawful basis for doing so. Most commonly, your information will be used in the following circumstances:

1. When needed to perform a contract entered into with you

2. When needed to comply with a legal obligation

3. When it is necessary for the legitimate interests of Lifeplus and your interests and rights under data protection law do not override those interests

Lifeplus Europe Limited May 2018

Lifeplus may also use your personal information, or special category information in the following situations, which are likely to be rare, and wouldn’t be considered part of the day to day processing activities of Lifeplus:

1. When needed to protect your interests (or some else’s interests)

2. Where it is needed in the public interest

The situations in which Lifeplus may process your personal information as part of the recruitment process are listed below:

 To communicate with you, where necessary

 Making a decision about your recruitment opportunity or appointment

 Determining the terms on which you will work for Lifeplus

 Checking that you are legally entitled to work in the UK

 Ascertaining your fitness to work

 Complying with health and safety obligations

 To prevent fraud

Some of the above reasons for processing may overlap, and there may be several grounds which justify the use of your personal information, or special category information. For further details please email privacy@lifeplus.com.

Failure to Provide Personal Information

If you fail to provide certain information when requested Lifeplus may not be able to fulfil some or all of its obligations to you, and / or may be prevented from complying with legal requirements.

If you feel that you are being requested to provide more personal information than necessary please email privacy@lifeplus.com.

How Special Category Information is Used

Special category information is considered more sensitive than personal information, and as such requires a greater level of protection.

Lifeplus is required to have further justification for processing this type of information, and will only do so in the following circumstances:

1. In limited circumstances, with your explicit written consent

2. Where required to carry fulfil a legal obligation or exercise rights in connection with your employment

3. Where it is needed in the public interest

Change of Purpose

Lifeplus will only use your personal information for the purpose(s) for which it was collected. In the event that it is needed for an unrelated purpose, Lifeplus will notify you and explain the lawful basis for the processing. Lifeplus Europe Limited May 2018

Information Regarding Criminal Convictions

Lifeplus will only collect information about criminal convictions where legally permitted. Information regarding criminal convictions will either be requested from you directly during your recruitment or appointment, or will be obtained from a suitable background check provider.

Data Sharing

During the course of your application to Lifeplus your personal information will only be shared with other members of the Lifeplus group of companies (including those located outside of the EEA).

Your personal information will be shared where necessary, and in the following circumstances:

 To make a decision about your recruitment or appointment

 To determine the terms on which you will work for Lifeplus

 Where Lifeplus has a legitimate interest in doing so

 Where required by law

Data Security

Lifeplus have put in place the appropriate and necessary security measures to protect your personal information, or special category information, from being accidentally lost, altered, disclosed or used or accessed in an unauthorised way. In addition, Lifeplus limits access to this information to only those employees, agents, contractors and other third parties who have a business need to know.

Lifeplus has a number of policies in place to safeguard your personal information, and special category information, and to deal with suspected or actual breaches of this information. For further details please contact privacy@lifeplus.com.

Data Retention

Your personal information will be processed for the duration of your recruitment journey with Lifeplus, and will then be retained for a further twelve months, in which time Lifeplus may contact you about other employment opportunities.

If you would like your contact details removed at any time, or would like to restrict how your personal information is processed, please see below on “Your Rights”.

Your Rights

Under certain circumstances you have the legal right to:

 Request access to your personal information

 Request, where applicable, that personal information held about you by Lifeplus is corrected

 Request erasure of your personal information

Lifeplus Europe Limited May 2018

 Object to the processing of your personal information where Lifeplus is relying on a legitimate interest as the lawful basis for that processing

 Request that the processing of your personal information is restricted

 Request that the personal information held about you by Lifeplus is transferred to another party

If you would like to enforce any of the above rights please contact Sam Arnold, Legal and Data Advisor (Sam.Arnold@Lifeplus.com) in writing.

Changes to this Privacy Policy

Lifeplus reserves the right to update this Privacy Policy at any time. This Privacy Policy was last updated in May2018.

Lifeplus Europe Ltd. – Cookie Policy

We are Lifeplus Europe Ltd.  Lifeplus Europe is the data controller and a data processor.  Our nominated representative for data protection and the purposes of the General Data Protection Regulation (EU/2016/679) is Sam Arnold. Our registered office is Lifeplus House, Little End Road, Eaton Socon, St. Neots, Cambridgeshire, PE19 8JH, England.  We may be reached at T +44 1480 224610; F +44 1480 224611; email to info.eu@lifeplus.com.

Lifeplus is committed to protecting your personal information and data while you are visiting our website to ensure that you can fully enjoy your visit. However, in order to operate our website we collect personal data as well as use cookies to give you the best possible browsing experience. The personal information and data we collect will vary depending on what you use our website for, but may include your name and email address, and your IP address. The collection of this information and data will either be temporary or permanent (until deleted) depending on what it is used for; likewise, our lawful basis for collecting and retaining this data may vary, but will either be contractual (for example, where you have an online Lifeplus account) or because of a legitimate interest (for example, to improve our service).

In case you should be unhappy that our website is storing cookies on your electronic devices, you have the opportunity to either block some or all of the cookies or even delete the cookies from your device which have already been set.  Further information on how to do this is provided below.

Please read the following Cookie Policy carefully before you start using our website. We also recommend that you check the Cookie Policy each time you visit this site in case something has changed since your last visit.

1. But, what is a Cookie?

A cookie is a small file, typically of letters and numbers, which a website transmits to the cookie file on the hard drive of the electronic device of the user when the user accesses certain websites. Cookies allow a website to recognise a user’s device and therefore to remember who you are. However, cookies cannot read any personal information on your electronic device; they simply unlock the electronic device memory and allow a website to recognise you when you revisit a website.    

There are two different durability types of cookies; so-called “Session” or “Persistent” cookies which enable your device to either remember information for the duration of your visit on the website (session cookies) or for repeat visits (persistent cookies). Session cookies get deleted from your device once you leave the website. Persistent cookies remain in a subfolder on your browser; a further visit on the website which originally placed the cookies on your electronic device will activate the cookie(s) again. Persistent cookies remain on your electronic device for a specific time. The exact duration of these cookies is variable, and may be viewed in the cookie’s file stored in a subfolder of your browser. Lifeplus does not store any cookie for longer than is necessary.

Cookies are also distinguished into three different necessity levels. Firstly, so-called “Strictly Necessary Cookies”, which are strictly necessary to enable you to move about the site or to provide certain features you have requested. This type of cookie cannot be disabled. Secondly, there are so-called “Functionality Cookies” used, which are cookies that enhance the functionality of website by storing your preferences. For example, these cookies allow us to remember your language preferences or your user name on the Lifeplus website. Thirdly, there are so-called “Performance Cookies”, which help to improve the performance of the website, providing a better user experience. These cookies do not collect information which could identify you. All information these cookies gather is anonymous and is only used to improve how our website works.

Furthermore, cookies are also differentiated into ‘First Party Cookies’ and ‘Third Party Cookies’. Whether a cookie is a first party or a third party cookie refers to the website or domain which places the cookie. First party cookies are placed by the website the user actually visits and third party cookies are cookies which are set by a domain other than the one visited by the user, hence the name third party cookies.

If you want to know more about cookies please have a look at the following link: http://www.allaboutcookies.org/.

1. How does Lifeplus use cookies?

We place cookies on your device to improve your browsing experience on our website. The following list tells which cookies we currently use:

Cookie	Name	Purpose
Lifeplus.com	PHPSESSID	The PHPSESSID cookie is native to PHP and enables websites to store serialised state data. On the Action website it is used to establish a user session and to pass state data via a temporary cookie, which is commonly referred to as a session cookie. As the PHPSESSID cookie has no timed expiry, it disappears when the client is closed.
Lifeplus.com	SecGUID	The SecGUID cookie is a persistent cookie added by Lifeplus.com to store additional security context during the login process to the secured portion of the website.  This cookie utilizes a unique ID that aids in the customer identification and simplifies the customer’s login process. If the cookie is deleted, the customer will be required to provide additional security context in order to gain access to the secured pages of the website.
Lifeplus.com	ASAP	The ASAP cookie is a session cookie used to save ASAP order information. The ASAP cookie is deleted once the user reaches the order confirmation page, or leaves the ASAP system.
Google Analytics		We use Google Analytics on our website. The cookies placed by Google Analytics are used to collect information about how our visitors use our site. This gives us a chance to improve our website for you. The Google Analytics cookies collect information in an anonymous form.  You can prevent the transmission of the data created by Google Analytics to Google and the processing of this data by downloading and installing a browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout?hl+en.
	_ga	Used to distinguish users, but does not collect personal information.
	_gid	Used to distinguish users, but does not collect personal information.
	_gat	Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.
localStorage		careersatlp.com uses localStorage to temporarily store customers’ selections in ASAP Online as they move from the initial order page to the review page so that they are able to return to the previous page via their browsers’ back button.

1. Links to other websites on our website

As you may notice, we also have a few third party links on our website such as the YouTube or Facebook buttons, which contain the potential of placing cookies on your electronic device when clicking on them. Please note that our Cookie Policy does not cover the links within our website linking to other websites of third parties. Therefore, we strongly encourage you to read the privacy statements and policies on the other websites you visit through links on our website.

1. Search engine

We also use a search engine on our website which was designed to be as powerful and easy to use as a popular search engine like Google or Yahoo. To make the search tool available we use a piece of hardware, a so-called search “appliance” which is a Lifeplus custom engine which is plugged into our server and continuously indexes the content on our website. Every search request is handled by the search tool appliance and the information is not forwarded to any third party.

1. What can I do to control cookies?

You have the possibility to change your browser settings so that you are able to accept or decline the placing of cookies or delete cookies which have been set on your hard drive.  Most of the web browsers allow its users control of most of the cookies through an amendment of the browser settings. If you would like to find out more about how you can change browser settings, how to view and manage cookies that have already been set on your device or delete cookies, please have a look on: www.aboutcookies.org or www.allaboutcookies.org.

1. Changes to our Cookie Policy

We regularly review our Cookie Policy to ensure that it is up-to-date. This Cookie Policy was last updated in April 2018.

1. How to contact us in case of any questions

Please address requests and questions about our Cookie Policy or Privacy Notice to our Legal and Data Advisor at Lifeplus Europe Ltd, Lifeplus House, Little End Road, St. Neots, Cambridgeshire, PE19 8JH, England or email us at privacy@lifeplus.com.