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Privacy and Cookies Policy

Privacy and Cookies Policy 

This Privacy and Cookies Policy (“the Policy”) applies to your use of the Volkswagen Financial Services (United Kingdom) Limited (“VWFS”) website at www.vwfscareers.co.uk (“the Website”).  It also applies to access from your computer, smartphone or other electronic Internet-enabled device.

The Website is operated by VWFS (“we”, “us”) (company registration number 2835230, VAT registration number 745963883), whose registered office is at Brunswick Court, Yeomans Drive, Blakelands, Milton Keynes MK14 5LR, a company authorised to conduct business in the United Kingdom.

  1. THE IMPORTANCE OF YOUR PRIVACY

Volkswagen Financial Services (UK) Limited (“the Company”) is a "data controller". Personal information collected through the Website is collected by VWFS for itself in its capacity as a “data controller” of that information. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

The contents of this policy may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we may also contact you directly to notify you of these changes.

This version of our Privacy Policy is live from April 2021.

What information do we collect?

VWFS operates the Website and you can visit it in an “information only” mode without telling us who you are or revealing any information about yourself. However, if you give us any personal information about yourself or others we promise to treat it securely, fairly and lawfully. We are committed to protecting your privacy.

To access and use the Website you will need to set up a secure login facility on your first visit and your personal information will also be used to facilitate this and to enable that secure login to operate each time you visit. 

When we ask you for personal information online it will only be in response to you actively applying for or using one of our online services. We may use personal information you provide for the purpose of providing more relevant content to you.

We may also collect, store and use personal information about you which includes some, or all, of the following:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  • Date of birth
  • Gender
  • Emergency contact information
  • National Insurance number
  • Financial information, including bank account details, payroll records and tax status information
  • Passport details 
  • Voice recordings of telephone calls
  • Identification documentation, such as copy of driving licence
  • mployment records relating to your employment at the Company, including working hours, training records and if you leave us, your reason for leaving
  • Disciplinary and grievance information and performance information
  • Photographs.
  • CCTV footage and other information obtained through electronic means such as swipe card records
  • Credit referencing information
  • Any information within correspondence you send to us
  • DBS checks (for certain roles within the Company)
  • Information relating to your current and past employment including details of salary.

We will during the course of our recruitment process also collect, store and use the following "special categories" of more sensitive personal information:

  • Data relating to race, ethnicity or nationality, religious beliefs and sexual orientation - this information will only be collected during the appointment process
  • Health data, including any medical condition or disability and health and sickness records which may include a workstation risk assessment, the results of which will be stored by us electronically

How do we collect your personal information?

We typically collect personal information about employees, workers and contactors through the application, recruitment and on-boarding process, either directly from candidates or from an employment agency or background check provider. We may collect additional information from third parties including former employers, credit reference agencies or other background check agencies. 

How do we use your personal information? 

VWFS will only process information that is necessary for the purpose for which it has been collected. You will always have the option to opt out of receiving marketing communications from us and you can withdraw your consent or object at any time (see below). We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else who might.

There are various ways in which we may use or process your personal information.  We list these below:

  1. You can use the Website to create your user account and it is a means through which you can submit requests or enquiries or an application for a job to VWFS.  We will use your personal information to:
  2. Assess your suitability and eligibility for the prospective role(s)
  3. Verify your identity and right to work in the UK
  4. Confirm your references and professional qualifications
  5. Comply with legislative and regulatory requirements
  6. Provide you with information about your prospective employment 
  7. Review and improve our recruitment process
  8. Gather evidence for possible grievance or disciplinary hearings
  9. Deal with potential legal disputes involving you 
  10. Maintain up to date and accurate internal records

Our lawful basis for doing so is the pursuit of our legitimate interests of recruiting individuals to join VWFS as part of our business plan, provided your interests and fundamental rights do not override those interests. We may use and process your personal information where this is necessary to perform a contract with you, for example, 

If you are not eligible to work in the UK, require a Company sponsor to work in the UK or have unspent criminal convictions, we will be unable to progress your online application for employment; this is an automated process. You have rights in relation to automated decision making; if you want to know more, please contact us. 

In addition, we may use your personal information for the following more general purposes:

  • to analyze trends and customer journeys across multiple locations;
  • to process and administer your user account;
  • to administer the Website;
  • for internal record keeping;
  • to contact you by fax, post, e-mail or phone for any of the above reasons, including as part of “information only” communications in which to communicate with you to inform you about the particular job roles which you have enquired about or have signed up to obtain through the Website;
  • subject to your prior consent, to carry out direct marketing including to send you marketing communications (further information below);
  • to notify you of changes in information about and updates concerning the Website;
  • where necessary as part of any restructuring or sale of the our respective businesses or assets; and
  • for compliance with our legal, regulatory and other good governance obligations.

We may also convert your personal information into anonymous form and use it (normally on an aggregated statistical basis) for research and analysis purposes, such as to improve the content on the In-Store Web Browser or the Website.

When you use the Website we may automatically collect standard internet and website log information and details of patterns about how visitors behave. The information includes but is not limited to information about your Internet service provider, your operating system, browser type, domain name, the Internet protocol (IP) address of your computer, smartphone or other electronic Internet-enabled device, your access times, the website that referred you to us, the pages of the Website you request and the date and time of those requests. This may allow us to find out which parts of the Website are popular or need changing.  Our collection of this type of Website use information may also involve the use of cookies. Please refer to the Cookies section below for more information.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How might we use particularly sensitive information?

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

  1. In limited circumstances, with your explicit consent;
  2. Where we need to carry out our legal obligations;
  3. Where it is needed in the public interest, such as for equal opportunities monitoring; or
  4. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.  

Why might we share your personal information with third parties?

We may share your personal information with third parties where required by law or where we have another legitimate interest in doing so. 

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group, including our HR and Payroll teams. The following activities are carried out by third-party service providers: payroll records, pension, occupational health, risk assessments, income protection and life assurance, and permanent health insurance, credit referencing, criminal checks, administration of employee benefit schemes and the provision of learning and development, data storage and database hosting services, IT hosting and IT maintenance services.

Our Website site may, from time to time, contain links to and from the websites of these selected third parties. 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 information to these websites.

When you use the Website you may find it includes links to websites operated by third parties and some of your personal information from your browsing session may be transferred to such third party websites.  Please refer to the Cookies section below for more information.

How secure is your information with third-party service providers and other entities in our group?

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.

When might we share your personal information with other entities in the group?

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may share your personal information with our insurers if you have to make a work-related injury/accident claim. We may also need to share your personal information with a regulator or to otherwise comply with the law – potential recipients include HM Revenue & Customs, the Department for Work and Pensions, District Councils, the Child Support Agency and Child Maintenance Service.

Will your personal information be transferred abroad?

We have described above how your personal information may be disclosed outside of VWFS.  We do not currently send your personal information outside the European Economic Area (EEA). However, if we change our policy on this, transfers outside the EEA may occur in the future.  For instance we may in future engage providers of services who are located outside the EEA, meaning that your personal information may be transferred to countries or territories located outside the EEA which do not have adequate protections for personal information. Steps will be taken with a view to protecting your personal information in that instance consistent with applicable data protection law.

What choices do we offer you with regard to direct marketing communications?

We may wish to provide you with information about new job roles that may be of interest to you.  This may occur by e-mail, telephone, post or SMS or other methods which are made clear to you from time to time.  We will obtain your prior consent and advise you of how to opt-out of receiving such communications in accordance with applicable data protection law. You may opt-out of direct marketing communications at any time by sending an e-mail to recruitment@vwfs.co.uk.

Please note that marketing communications are separate and distinct from “information only” communications and that consents are not usually required in order for us to communicate with you to inform you about a particular job which you have enquired about or have signed up to obtain details of through the Website, using contact details you have provided for this purpose.    

How do we keep your information secure?

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.

How long do we retain your information for? 

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, after which we shall destroy your personal information in accordance with our Record Retention policy.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

In the case of prospective employees who are not offered employment with VWFS, this means that, in most circumstances we will retain their personal data while the recruitment process is ongoing and for 12 months after it ends.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your dealings with us. 

What rights do you have in respect of your personal information?

Under certain circumstances, by law you have the right to:

Withdraw consent to the collection, processing and transfer of your personal information for a specific purpose at any time. To withdraw your consent, please contact recruitment@vwfs.co.uk. Upon receipt, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party. 

If you wish to enquire about or exercise any of these rights, please contact recruitment@vwfs.co.uk

You will not usually have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

How can you make a complaint? 

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. The ICO’s contact details are as follows:

Information Commissioner's Office
 Wycliffe House
 Water Lane
 Wilmslow
 Cheshire
 SK9 5AF

Call: 0303 123 1113

If you wish to raise a complaint to the ICO, you can do so via their website under ‘Make a complaint’ on the attached link https://ico.org.uk/make-a-complaint/. 

If you have any questions about this privacy notice, please contact recruitment@vwfs.co.uk.

2. Cookies Notices

Cookies are text files that are stored on your computer, smartphone or other electronic Internet-enabled device when you first access the Website and when you revisit certain pages of the Website thereafter.  We may update the Cookies section of this Policy (as set out below) from time to time, for instance when we propose to install additional cookies on users machines or other devices on their next visit to the Website.  Steps will be taken to draw this to the user’s attention and to collect appropriate new consents at that time, where necessary. 

How do we use cookies?

Some of the cookies we use help us to maintain the Website, while others remember the pages and models you look at when you first visited the Website and to help to improve your Website experience each time you visit.

We also use cookies to track how you use the Website by providing usage statistics. Whilst this information on its own does not usually contain your personal information, we may combine the information we collect by cookies with personal information that we have collected from you in order to learn more about how you use and how we can improve the Website.

Cookies we use

Some of the cookies we use are necessary to enable you to move around the Website and use its features such as accessing secure areas that may contain content for registered users.

We also use functional cookies to record information about the choices you have made and to allow us to tailor this Website to our users; for example, to remember your language or region or that you have already completed a survey. This information is usually anonymised and is not used for any purpose unrelated to the Website.

We or our service providers also use analytic services to help us understand how effective our content is, what interests our users have, and to improve how the Website works. In addition, we use web beacons, tracking pixels and similar services to understand more about the visitors to this Website, and to count visitor numbers and performance cookies to track how many individual users access the Website and how often. This information is used for statistical purposes and to improve how the Website works and it is not our intention to use such information to personally identify any user. However, if at any time you register and sign into the Website we may combine such data with information from our web analytic services and cookies to analyse how you use the Website in more detail.

This Website does not use targeting cookies to deliver targeted advertising on the Website; however, these cookies may be used on third party websites on which we occasionally advertise, to track the success of those advertising campaigns. We may use web beacons (also known as pixel tags) to determine which users have come to the Website after viewing an advertisement we have served on such third party websites. We also work with such third parties to collect data so that we can determine the effectiveness of our ads and serve ads targeted to your interests. The use of web beacons does not provide us with any personal information and we do not use this technology to access your personal information. It is used only to compile aggregated data about users who visit this Website and to gauge the effectiveness of our ads. Web beacons do not place information on your device, but may work in conjunction with cookies to monitor activity. You cannot remove or block web beacons, but you can remove or block cookies with which they work to block the collection of information about your user activity.

Contact/address details

If you have any questions about the cookies we use, please contact VWFS (the company which operates this Website) at recruitment@vwfs.co.uk.

Last revised: April 2021

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