Sims Metal Candidate Privacy Notice

What is the purpose of this document?

Sims Metal Management is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, 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 (GDPR).

Data protection principles

 In accordance with data protection law. The personal information we hold about you will be:

1. Used lawfully, fairly and in a transparent way.

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

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

The kind of information we hold about you

In connection with your application for work with us, we may collect, store, and use the following categories of personal information about you:

• The information you have provided to us in the application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, experience.

• Any CV or covering letter submitted.

• Any information you provide to us during an interview.

We may also collect, store and use the following “special categories” of more sensitive personal information about:

• your race or ethnicity, religious beliefs, sexual orientation and political opinions.

• your health, including any medical condition, health and sickness records.

• criminal convictions and offences.

How is your personal information collected?

We will collect personal information from you and in some cases also from the following sources:

• Your named referees, from whom we request the following categories of data: dates of previous employment, role, responsibilities, performance.

• The RISK ADVISORY GROUP LIMITED background disclosure check provider, from which we collect the following categories of data: Residency, Academic History, Employment History (for your last two roles) and ID verification such as a passport.

How we will use personal information about you

We will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the work/role.

• Carry out background and reference checks, where applicable.

• Communicate with you about the recruitment process.

• Keep records related to our hiring processes.

• Comply with legal or regulatory requirements.

• To determine whether to offer you a position.

It is in our legitimate interests to consider this information in the recruitment process to enable us to identify the best candidate for vacancies.

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.

How we use sensitive personal information

We will use your particularly sensitive personal information in the following ways:

• We will use information about your health and disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview or to the role applies for.

• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Information about criminal convictions

We may collect information about your criminal convictions history if we would like to offer you a role (conditional on checks and any other conditions, such as references, being satisfactory). We are entitled to carry out a criminal record check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. We carry this out for all roles.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Data sharing

We will only share your personal information with the following third parties for the purposes of processing your application: The Risk Advisory Group Limited 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 have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, 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 put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention We will retain your personal information for a period of six months after we have communicated to you our decision about whether your application has been successful. We retain your personal information for that period: 1. 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; and 2. on the basis that a further opportunity may arise in future and we may wish to consider you for that (we may retain the information for this purpose for longer with your express consent). After this period, we will securely destroy your personal information in accordance with our data retention policy.

Changes to this privacy notice

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 that affect you.

Rights of access, correction, erasure, and restriction

If you wish to exercise any of your rights in relation to your data, please contact the Legal Department.

Privacy Champion

We have appointed a Privacy Champion to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Legal Department on You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

If you have any questions about this privacy notice, please contact the Privacy Champion,

Updated November 2021